Ezel / IRS Rulings / 1333010
Chief Counsel Advice 1333010 Released August 16, 2013 Advice

CCA addresses replacement property for involuntarily converted livestock

Apply this to your situation

This page covers one taxpayer's ruling from 2013, which can't be cited as precedent. Ask about your situation and see what the current Code and IRS guidance say, with citations.

Currency note: this determination was released in 2013
Statutory amendments, regulation changes, court decisions, or later IRS guidance may have changed the analysis since then. Treat this page as historical context, not current tax advice. Verify current law before relying on any specific rule, threshold, or position mentioned here.
Not precedent. Under 26 U.S.C. § 6110(k)(3), this written determination may not be used or cited as precedent. It resolved one taxpayer's situation on its specific facts, and identifying details were redacted by the IRS before release. The official IRS release (linked on this page as a PDF) is the authoritative source.
About this page: The plain-English summary and ruling snapshot below were written by Ezel based on the official IRS release. The full text is the IRS's own document.
View official IRS release (PDF)

Plain-English summary

Chief Counsel Advice states that a taxpayer may replace livestock with other property used for farming under IRC § 1033(f) when replacing it with property similar or related in use is not feasible because of weather-related conditions or environmental contamination. The advice distinguishes those conditions from market conditions, which do not provide the same basis for using other farming property as replacement property.

Ruling snapshot

  • Question: When may a taxpayer replace involuntarily converted livestock with other property used for farming under IRC § 1033(f)?
  • Outcome: Advice given. Weather-related conditions or environmental contamination may make similar or related-use replacement property infeasible; market conditions do not.
  • Key authorities: IRC § 1033(f).

Full text (IRS public release)

ID: CCA-516123-13
Office: -------------
UILC: 1033.00-00
Number: 201333010
Release Date: 8/16/2013
From: -------------------
Sent: Thursday, May 16, 2013 2:22 PM
To: --------------
Cc: -------------------
Subject: RE: Question about Code Section 1033(f)

Yes, I think we're in agreement. A taxpayer can replace livestock with "other property . . . used for
farming" under section 1033(f), if replacing the livestock with "property similar or related in use" is not
feasible due to weather-related conditions or environment contamination. A taxpayer can't replace
livestock with "other property . . . used for farming" because of market conditions, for example.

Get today's answer for your situation

You just read what the IRS ruled for one taxpayer in 2013, and it can't be cited as precedent. Ezel checks the current Internal Revenue Code and IRS guidance and answers your specific situation, with citations.

Opens in Ezel Pro. Every answer cites the authority it relies on.