This is a long shot but I can't find any IRS guidance in the form of Regs or PLRs.
A client, organized as an LLC, wants to know if they can purchase two buildings to meet the threshold to avoid taxes on the insurance settlement for a building rendered inhabitable by fire. (The fire was not the fault of the client.)
The code only refers to property but does not specifically address if two $5,000,000 buildings can replace a $10,000,000 one.
You should be able to use IRC Section 1033(b)(3)(D)(ii) to support the multi-property answer.
Here's Section 1033(b)(3)(D)(ii): "(ii) Allocation of reduction among properties If more than 1 property is described in a clause of subparagraph (C), the reduction under this paragraph shall be allocated among such property in proportion to the adjusted bases of such property (as so determined)."
Also, the term "a property" isn't used to refer to the replacement property, it's always referred to as "property."
Clarification: The term "a property" isn't used **in the Internal Revenue Code** to refer to the replacement property, it's referred to in the Code as "property." Some authors, however, writing about this topic, *mistakenly* refer to the replacement property as "a property." I think that's wrong, and misleading, and shows that sometimes people who write don't know what they're writing about.
Thank you
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