The uses of every possession are two, both dependent upon the thing itself, but not in the same manner, the one supposing an inseparable connection with it, the other not; as a shoe, for instance, which may be either worn, or exchanged for
something else, both these are the uses of the shoe; for he who exchanges a shoe with some man who wants one, for money or provisions, uses the shoe as a shoe, but not according to the original intention, for shoes were not at first made to be exchanged.
Thus, if the FMV of the property exchanged equaled the FMV of the annuity contract received, the investment in the latter will equal the FMV of the property exchanged for
The shares were exchanged for
$8.3 billion in cash and notes, plus approximately $440 million in warrants to purchase DuPont shares, approximately $56 per share in total.
264(a)(4) "a policy exchanged for
a policy issued by a different insurance company would be treated as a new contract .
168(f)(7) were still in effect, T would continue to depreciate the remaining $9,000,000 over the next nine years, even if the building were exchanged for
another office building in a Sec.
1.1031(a)-1(b), real property exchanged for
real property qualifies as like-kind, regardless of the property's state of improvement.
1031(a)(1) provides for nonrecognition of gain or loss when property held for investment or trade or business use is exchanged for
like-kind property held for investment or trade or business use.
1031 allows for non-recognition of gain when property held for investment or trade or business use is exchanged for
354 and 356 (nonrecognition treatment) if, in pursuance of the plan of reorganization, securities of the surviving corporation are exchanged for
securities of the controlling corporation or for other securities of the surviving corporation.
1031 (a)-1 (b) states that "like-kind" property refers to the nature or character of the property, not to its grade or quality; thus, real property exchanged for
real property will qualify as like kind regardless of the state of improvement of the property.
The taxpayer's relinquished property was a single parcel of unimproved land, which was exchanged for
several different replacement properties.
Thus, a rental building exchanged for
a building that the taxpayer intends to use as his or her personal residence does not qualify as a like-kind exchange; compare Dollie Click, 78 TC 225 (1982), with Fred S.
Thus, land can be exchanged for
improved real estate under Regs.
Personal property must be exchanged for
personal property, and real property for real property;
If automobiles and computers are exchanged for
other automobiles and computers, two exchange groups are created, one consisting of the automobiles transferred and received and the second consisting of the computers transferred and received.