@M-MTax wrote:
I would expect that there would be an exception to the holding period for inherited property, similar to the long term capital gains rule.
Probably not because we're talking about a revenue procedure that provides a safe harbor....any exception would have been included in that procedure while the "long term capital gains rule" is codified....it's in the internal revenue code.
Are you just being silly? The reason it is called a section 1031 exchange is because it is provided for in section 1031 of the Tax Code.
https://www.law.cornell.edu/uscode/text/26/1031
And here's the Treasury Regulations that implement the code.
https://www.law.cornell.edu/cfr/text/26/1.1031(a)-1
Any revenue procedure that describes how taxpayers can implement the code and regulations to be deemed to be in compliance, is nevertheless subordinate to the code and regulations, and can't add rules and requirements not in the regulations or code. The regulations and code don't include a holding period.
