Corpus

Partnership holding appreciated warehouse ($12M FMV, $4M basis, $3M debt) with two 50% partners seeking divergent exit strategies: one partner wants cash, the other wants Section 1031 exchange. Partners had substantive price negotiations ($11.5-12.5M range) with potential buyer six weeks before contemplating distribution of property to partners as tenants-in-common, with written communications showing exit intent two months prior.

Family and co-investors held appreciated commercial property ($15M FMV, $4M basis) in partnership-taxed LLC. Majority partner sought to 1031 exchange into individually-owned replacement property while minority partners wanted cash liquidity. Partnership executed formal dissolution distributing property to majority partner and cash to minority partners, followed 60 days later by majority partner's individual Section 1031 exchange into pre-identified Dallas replacement property.

Partnership holding appreciated commercial property ($8M basis, $25M FMV) with GP (30%) and three institutional LPs (70%) seeking divergent Section 1031 exchanges—GP targeting Denver multifamily, LPs targeting Phoenix industrial. Partnership executed swap-and-drop: exchanged into both properties, operated 18-24 months with preferential allocations giving each partner economic benefits tied to their preferred asset, then liquidating dissolution distributing properties along pre-negotiated lines.