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1031 tax free exchange?

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    1031 tax free exchange?

    Corp. A is a majority partner in a partnership which owns land. My client is a minority partner in the partnership. Corp. A wants to buy my clients interest in the partnership.
    Question: If my client takes Class B stock in corp. A in exchange for his partnership interest in the land, would this qualify for a sect. 1031 tax free exchange?
    Or would tax have to be paid on any gain?
    Thanks.

    #2
    Section 1031(a)(2)(D) says the nonrecognition of gain rules do not apply to an exchange of a partnership interest.

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      #3
      Like-kind rules

      Like-kind rules for intangibles are not as wide-open as for real estate. You have to match the specific rights being traded. In any case, corporate stock is never eligible for 1031 treatment.

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        #4
        Thanks

        to both of you for your response.

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