Priv. Ltr. Rul. 200826005 (Mar. 17, 2008)

(undivided fractional interest in rental properties that are co-owned by unrelated business entities does not constitute an interest in a business entity under Treas. Reg. §301.7701-2(a) and, therefore, does not qualify the undivided fractional interest as eligible replacement property under I.R.C. §1031(a)). 

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