1033 voluntary conversion

[mhcpa1964]

Title should be Involuntary Conversion - can't seem to edit it

Can you assist with 1033 conversion. Power plant purchased via an easement property of an S Corp. Conversion and proceeds occurred in 2022 and gain has been deferred.
Assets identified in the conversion are land, land improvements, fencing and a warehouse.

Does the replacement property need to be purchased within 2 years or 3 years? I was thinking 3 years since it's business real property. The legal documents list the subject as "tax parcel number XXX". Is this sufficient for a 3 year replacement?

Next, in 2023 client paid for improvements to the property as a result of the easement's changes to the land. They had to replace fences and redo driveways, among other improvements. Can or should these improvements affect the deferred gain? It seems plausible to me but I'm not sure if the replacement property has to be strictly something new and not the remaining existing property. The easement was NOT for the entire real estate client owns.

And would it help to know the client is a used car/vintage car sales company?

Thanks for your time and offerings.

[mhcpa1964]

I'll chime in lol. I believe the improvements to the remaining parcel (which were due to the involuntary conversion) won't qualify as replacement property. Title to a new property has to be exchanged. And the replace,ent has to be equal to or higher than the conversion proceeds. Now I'm checking on the mix of the affected property to be sure it qualifies for 3 year replacement term. I think the Masser Doctrine affirms this.