Legal Opinion
Ocmulgee Fields, Inc. v. Comm. of Internal Revenue
Court of Appeals for the Eleventh Circuit
Decided August 13, 2010No. 09-13395PublishedCited by 21 opinions
1Opinion of the Court
EBEL, Circuit Judge:
Although in most circumstances, a taxpayer must immediately recognize gains realized from the sale of his property, see 26 U.S.C. § 1001(c), 1 a taxpayer may receive nonrecognition treatment for gains realized from the disposition of property through a qualified like-kind exchange under § 1031(a). Special rules, however, disallow nonrecognition treatment for certain like-kind exchanges that involve a related party, directly or otherwise. See § 1031(f). At issue in this case is § 1031(f)(4), which disallows nonreeognition treatment for any like-kind exchange that was “part…
2Cases cited9 opinions
- T. J. Starker v. United StatesCourt of Appeals for the Ninth Circuit · 1979
- Redwing Carriers, Inc. v. TomlinsonCourt of Appeals for the Fifth Circuit · 1968
- Slappey Drive Industrial Park v. United StatesCourt of Appeals for the Fifth Circuit · 1977
- Emsy H. Swaim and Annie Swaim, Cross v. United States of America, CrossCourt of Appeals for the Fifth Circuit · 1981
- Atlanta Athletic Club v. Commissioner of Internal Revenue ServiceCourt of Appeals for the Eleventh Circuit · 1993
4 more not listed; retrieve them via the Exa API.
3Cited by21 opinions
- United States v. Sally JimCourt of Appeals for the Eleventh Circuit · 2018
- Philip Long v. Commissioner of IRSCourt of Appeals for the Eleventh Circuit · 2014
- Cadwell v. CommissionerUnited States Tax Court · 2011
- David B. Greenberg v. Commissioner of Internal RevenueCourt of Appeals for the Eleventh Circuit · 2021
- Deseret Management Corporation v. United StatesUnited States Court of Federal Claims · 2013
16 more not listed; retrieve them via the Exa API.