During the past decade there has been a significant increase in the number of taxpayers engaging in Internal Revenue Code Section 1031 like-kind exchanges. In 2003, the last year for which data was published by Deloitte Tax LLP, there were an estimated 220,000 transactions involving about $105 billion in equity. As the popularity of 1031 exchanges has grown, the issues surrounding these transactions naturally have evolved. Recently, several qualified intermediaries' defalcation of exchange
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