Ezel / IRS Rulings / 201333010

CCA addresses replacement property for involuntarily converted livestock

Number
201333010
Outcome
Advice
Document type
Chief Counsel Advice
IRS subject
Involuntary Conversion
Topics
Property transactions and exchanges
Code sections
§ 1033
Ruling dated
May 16, 2013
Publicly released
August 16, 2013
Source
View Official PDF

Apply this to your situation

This page covers legal advice the IRS Office of Chief Counsel wrote for IRS staff, issued in 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 is advice from the IRS Office of Chief Counsel to IRS personnel on the facts they presented, 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.

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