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Rev. Proc. 2004-51
- Article from:
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United States. Internal Revenue Bulletin
- Article date:
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August 16, 2004
- Author:
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Copyright informationCopyright Superintendent of Documents Aug 16, 2004. Provided by ProQuest LLC. (Hide copyright information)
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SECTION 1. PURPOSE
This revenue procedure modifies sections 1 and 4 of Rev. Proc. 2000-37, 2000-2 C.B. 308, to provide that Rev. Proc. 20007 -37 does not apply if the taxpayer owns the property intended to qualify as replacement property before initiating a qualified exchange accommodation arrangement (QEAA).
SECTION 2. BACKGROUND
.01 section 1031 (a) provides that no gain or loss is recognized on the exchange of property held for productive use in a trade or business or for investment if the property is exchanged solely for property of like kind that is to be held either for productive use in a trade or business or for investment.
.02 Section 1031 (a)(3) allows taxpayers to structure ...