IRS C.C.M. 20115101F (Nov. 14, 2011)

(income received from compelled lease of property that was held as rental property is includible in income and the involuntary conversion rules of I.R.C. Sec. 1033 do not apply; on the question of whether I.R.C. Sec. 1033 applies to a temporary taking of property, IRS reasoned that it did not because a fee interest was not taken and proceeds allocable to property was in nature of rent taxable as ordinary income in year of receipt).