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