CCH Federal Taxation Basic Principles
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Receiving like-kind property before giving like-kind property is known as a “reverse-Starker” transaction. IRS TAKES THE POSITION THAT Code Sec. 1031 DOES NOT APPLY TO REVERSE-STARKER TRANSACTIONS! [Preamble to final regulations, 56 Fed. Reg. 19933 (5/1/91)]
Thus, in a two-party exchange where like-kind property is exchanged at different times, one party may qualify for Code Sec. 1031 while the other party may not!
Like-Kind Exchanges—Reverse Starker Transactions
Chapter 11, Exhibit 13c