Related Persons: Always Check the Definition - A Lesson from Like-Kind Exchanges

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2009-06-05
Authors
Harl, Neil
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Abstract

When encountering the term “related party” or “related person” in a statute, it is always important to check the definition.1 For example, the definitions for the two provisions designed to combat abuse in the installment sales area – the so-called two-year disposition rule2 and the sale of depreciable property rule between related persons3 – have vastly different “related person” rules4 even though they are stabled in the same section of the Internal Revenue Code and deal with similar problems in the abuse area.

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