Rev. Proc. 2002-22 (.pdf)
This revenue procedure specifies the conditions under the Internal Revenue Service will consider a request for a ruling that an undivided fractional interest in rental real property (other than a mineral property as deifned in section 614) is not an interest in a business entity, within the meaning of §301.7701-2(a) of the Procedure and Administration Regulations.
Rev. Proc. 2002-22 vs. 1031 Xpress Program (.pdf)
Rev. Proc. 2002-22 specifies the conditions under which the Internal Revenue Service will consider a request for a ruling that an undivided fractional interest in rental real property is not an interest in a business entity, within the meaning of §301.7701-2(a) of the Treasury Regulations.
Rev. Proc. 2002-69 (.pdf)
The Treasury Department and the Internal Revenue Service have become aware that taxpayers are unsure of the classification for an entity that is owned solely by a husband and wife as community property under the laws of a state, a foreign country, or possession of the United States. To alleviate this uncertainty and in the interest of administrative simplicity, this revenue procedure that the Internal Revenue Service will respect a taxpayer's treatment of these entities as either disregarded Entities or partnerships.
P.L.R. 200327003 Partnership defined (.pdf)
A company (Y) intends to acquire a fee interest in commercial real property (the "Property") with its own funds. The Property will be free of liens. Y wil lease the Property to a single corporate tenant (the "Lessee"). Rents under the lease will be at fair market and will not depend on the income or profits derived by any person from the leased Property. The lease will be a triple net lease, under which the lessee is responsible for all costs related to the Property, including real estate taxes, maintenance, insurance, and repair (the "Lease").
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