C.C.M. 201238027 (Apr. 17, 2012)

(federal law and not state law controls the determination of whether property involved in a like-kind exchange satisfies the definition of "like-kind"; while state law property classifications are relevant for determining whether property is real or personal, federal law determines whether the properties are of the same nature or character; natural gas pipeline, while real property in one state and personal property in another state, are of the same nature and character and are like-kind for purposes of I.R.C. Sec. 1031 and will be treated as real property land improvements; but, associated steam turbines are not to be treated as real property and are not part of the exchange group under I.R.C. Sec. 1031).