Can 2 Contiguous Properties Be Considered One Property in a 1031 Exchange?

Two contiguous properties with separate postal addresses may could still be considered one property (for the purposes of the three-property rule for designating replacement property for 1031 exchanges), such as a duplex, or a farm with adjoining land in two different counties, cities, or states.

Please review Rev. Proc. 2002-22: https://www.irs.gov/pub/irs-drop/rp-02-22.pdf 

Even if they are non-contiguous parcels of property, if they operate as a single economic unit (for example, an office building and a garage that services the tenants of the office building) may be treated as a single business unit even if the office building and the garage are not contiguous.

The IRS will generally treat contiguous parcels as comprising a single business unit. Even if the parcels are not contiguous, however, the IRS may treat multiple parcels as comprising a single business unit where there is a close connection between the business use of one parcel and the business use of another parcel.

The question is will the IRS treat a Delaware Statutory Trust (“DST”) as a single economic unit and deem it to be one property for 1031 identification purposes.

The safe play is to assume that a DST that is comprised of multiple non-contiguous parcels of property takes up multiple slots under the three-property rule.

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