Journal Issue:
Agricultural Law Digest: Volume 16, Issue 23

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Cases, Regulations, and Statutes
( 2005-12-02) Achenbach, Robert ; Iowa State University Digital Repository
Exchanging Fractional Interests in Property
( 2005-12-02) Harl, Neil ; Iowa State University Digital Repository

For years, since 1984,1 interests in a partnership have been considered ineligible for like-kind exchange treatment.2 A partnership can, of course, exchange assets with another individual or entity but partnership interests are not like-kind.3 In 1997, the Internal Revenue Service ruled that, in some circumstances, fractional interests in otherwise eligible property may be deemed a partnership with the result that the exchange is not like-kind.4 That development produced an outcry from taxpayers and tax practitioners with IRS agreeing to study whether undivided fractional interests should be considered eligible for like-kind exchange treatment.5