The U.S. Court of Appeals has now joined the Ninth and Eleventh Circuits, in finding that inserting a qualified intermediary between related parties does not avoid I.R.C. Sec. 1031(f). The plaintiff, a subsidiary of a Caterpillar dealer that sold Caterpillar equipment, ran the dealer's rental and leasing operations. The plaintiff sold used equipment to third parties who then paid the sales proceeds to a qualified intermediary. The qualified intermediary forwarded the sales proceeds to the dealer who then purchased new Caterpillar equipment for the plaintiff and then transferred the new equipment to the petitioner through the qualified intermediary. The arrangement provided favorable financing from Caterpillar and the dealer had up to six months from the invoice date to pay Caterpillar for the petitioner's new equipment. The petitioner claimed the transaction was non-taxable as a like-kind exchange. The trial court agreed with the IRS that the transactions failed I.R.C. Sec. 1031(f) and the appellate court agreed. The court determined that the case was factually similar to Ocmulgee Fields (10th Cir 2010) and Teruya Bros. (9th Cir. 2009). North Central Rental and Leasing v. United States., No. 13-3411, 2015 U.S. App. LEXIS 3383 (8th Cir. Mar. 2, 2015), aff'g., No. 3:10-cv-00066 (D. N.D. Sept. 3, 2013).