Revenue Rulings

• Rev. Rul. 2002-83:  Related Party Exchanges -- Addresses the issues of related parties exchanging properties with one another, and also exchanges in which the Taxpayer acquires Replacement Property from a related party.

• Rev. Rul. 2003-56:  Partnership Debt in a Tax-Deferred Exchange -- Addresses the issue of reporting increases or decreases in partnership debt as a result of a Section 1031 Exchange that straddles two tax years.

• Rev. Rul. 2004-86:  Delaware Statutory Trust -- Tenant-in-Common interests, beneficially owned by Taxpayers through a Delaware Statutory Trust structure, can qualify for nonrecognition under IRS Section 1031.

• Rev. Rul. 72-456, 1972-2 C.B. 468 :  Expenses and Fees in a Multi-Party Exchange: Broker's Commissions -- Demonstrates the proper accounting treatment in Section 1031 Exchanges for real estate broker fees, along with the calculation of the basis for the replacement property.

• Rev. Rul. 89-121, 1989-47 :  I.R.C. Multi-Asset Exchange -- In a clarification of Revenue Ruling 85-135, the IRS ruled that in an exchange of assets of one business for assets of another, the extend of non-recognition depends on the nature of the underlying assets.

• Rev. Rul. 90-34:  Direct Deeding -- Confirms that a Taxpayer in a Section 1031 Exchange can deed his Relinquished Property directly to the Purchaser, and for the Seller of the Replacement property to deed it directly to the Taxpayer.  The deeds need not run through the Qualified Intermediary.

• Rev. Rul. 92-105:  Illinois Land Trusts -- For the purposes of Section 1031, the beneficial interest in an Illinois Land Trust is considered an exchange of the underlying real property and not an exchange of a certificate of trust or beneficial interest.