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Abstract

Issuance of Notice 2000-41 more than four years ago was greeted by surprise and consternation by many taxpayers and practitioners alike.2 That Notice, for like-kind exchanges and involuntary conversions, discarded the established procedure of adding the undepreciated value of assets traded or otherwise relinquished to the cash boot paid to establish the income tax basis for the acquired property.3 Rather, the Notice specified that, to the extent the income tax basis of the acquired property exceeds the basis in the exchanged property, the newly-acquired property is to be treated as newly-purchased MACRS property.4 Thus, two separate depreciation deductions were needed for each item of property, one for the carryover basis with the depreciation deductions claimable over the remaining recovery period and the other for the portion of the basis attributable to the additional amount paid, which is depreciated as newly-acquired property over the recovery period for the acquired asset.5

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