(taxpayer is an LLC treated for tax purposes as a partnership and is owned in-part by a disregarded entity for federal tax purposes; disregarded entity is wholly owned by LP and is partially owned by a management company that is a real estate investment trust (REIT) that is wholly owned by LP; LP is also affiliate of a trust - a publicly held statutory REIT; taxpayer is related to LP for purposes of I.R.C. Sec. 1031; taxpayer owned retail building and wants to enter into sale agreement with unrelated third party; taxpayer to then enter into exchange agreement with qualified intermediary to which rights of transaction will be assigned; replacement property; replacement property is vacant urban office building which is subleased by ground lessee that is a wholly owned by LP; building to be demolished then vacant land to be subleased to exchange accommodation party or sublease to exchange accommodation party which will then demolish building; sublease to have term of over 30 years and interests not to be disposed of within two years; transaction qualifies for like-kind exchange treatment).