References in periodicals archive ?
The accommodation party holding title to the replacement property must not be the taxpayer's agent.
2000-37 safe harbor, most tax advisers have counseled taxpayers to use an accommodation party who meets the QI definition to avoid unnecessarily exacerbating the agency issue.
Accordingly, this revenue procedure provides a safe harbor that allows the taxpayer to treat the accommodation party as the owner of the property for Federal income tax purposes, thereby enabling the taxpayer to accomplish a qualifying like-kind exchange.