Articles From Elizabeth S. Tenney

The tax treatment of tenant-in-common ownership interests in a like kind exchange is now the subject of a recently issued revenue procedure By Edward J. Hannon & Elizabeth S. Tenney Federal Taxation, June 2002 On March 20, 2002, the Internal Revenue Service (IRS) issued Revenue Procedure 2002-22, which sets forth the conditions under which the IRS will consider a request for private letter ruling on the issue of whether an undivided fractional interest in real property qualifies as qualifying replacement property for purposes of the tax-free like kind exchange rules of Code Section 1031.

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