IRS Private Letter Ruling PLR 200251008

(“Exchangor" or "Exchanger") Individual or entity desiring an exchange. Taxpayer is an S corporation, organized under the laws of State A, which operates Business on a calendar year basis, using the accrual method of accounting. Business is situated on RQ. (“Exchangor" or "Exchanger") Individual or entity desiring an exchange. Taxpayer owns a fee interest in RQ, with all improvements thereon.

CorpW, an S corporation organized under the laws of State A, currently leases A-Acres situated on Unimproved Real Property located in City and County under a Lease and Development Agreement (“Lease”), as amended, with City. Lease’s term is 45 years from the commencement date (which was on or about September 2, 1997), and one 15- year renewal option.

LLC-W, a State A limited liability company, subleases A-Acres from CorpW and all rights, title, interest and obligations under Lease, for the entire term of Lease. LLC-W plans to utilize A-Acres, in part, as the new location for Business that presently exists on RQ. LLC-W is currently developing and constructing the infrastructure required so that Business can be moved to A-Acres.

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