For each of the following involuntary conversions, determine whether the property qualifies as replacement property.
a.
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Chuck’s restaurant building is destroyed by fire. He clears the site and builds another restaurant building. b.
?
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Diane’s warehouse, which she used for storing inventory, is destroyed by a tornado. She purchases another warehouse in which she will store inventory. c.
?
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Part of Andrew’s dairy farm land is condemned to make way for an interstate highway. He uses the condemnation proceeds to construct a barn to be used for storing cattle feed. d.
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Liz owns a shopping mall that is destroyed by a flood. Since the tenant occupancy rate was down, she uses the insurance proceeds to purchase an office building that she will rent to tenants. e.
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Eleanor’s Maserati Gran Turismo is stolen. The original cost was $125,000, and she had used it exclusively for personal use. Due to the limited supply of this model, it had appreciated in value. Eleanor received insurance proceeds of $130,000 and uses the proceeds to purchase a replacement Gran Turismo.
What will be an ideal response?
All of the replacements qualify as replacement property for purposes of an involuntary conversion. Items a., b., and e. qualify under the functional use test; item c. qualifies under the special rule for condemned realty; and item d. qualifies under the taxpayer use test.
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