Involuntary Conversions: page 399
1.    1033(a): when your property is destroyed, stolen or seized, w/out the non-recognition protection of 1033, gain realized as a result of the involuntary conversion of property would be recognized, despite the involuntary nature of the event.
2.    §1033(a) defines involuntary conversion of property to include destruction, in whole or in part, by theft, seizure, the requisition or condemnation of property, or the sale of property under threat or imminence of requisition or condemnation.
a.    Direct conversion into other property, or
i.    w/ direct conversion, non-recognition is mandatory
b.    In direct conversion, reinvest the proceeds from the conversion
i.    w/ indirect conversion, non-recognition is elective
1.    the election in an indirect conversion can be made in the year of the conversion or in the year of the replacement, w/ failure to elect resulting in the recognition of realized gain (1.1033(a)-2(c)(2), (3)).
c.    an indirect conversion into qualified property must be by purchase.
d.    1033(a)(2)(A)(ii): provides that a taxpayer is considered to have purchased the property if, but for §1033(b), the unadjusted B of the property would be its const.
e.    T/f the acquisition of replacement property by gift or by another transaction resulting in a B other than cost wouldn’t qualify under 1033
3.    when you lose the property, 1033(a)(1) and (a)(2)(A) require that the replacement property be “similar or related in service or use” to the converted property.
a.    1033(g)(1) provides a more liberal like kind replacement rule, however, for certain types of condemned property.
i.    business or trade use real property
ii.    1.1033(g)-(1)
iii.    this like kind standard is more strict than 1031
4.    1033(a)(2)(B) requires generally that the replacement property be purchased by the taxpayer-owner within a period:
a.    beginning w/ the date of the disposition of the converted property by destruction, theft, condemnation, etc., or the date on which the condemnation or requisition was fist threatened or became imminent, whichever  is earlier; &
b.    ending two years after the close of the first taxable year in which any party of the gain on the conversion is realized.
i.    For involuntary conversion of real property into like-kind property that qualifies under 1033(g), the replacement period is extended to three years by 1033(g)(4)
5.    the B of replacement property received in a qualified transaction is determined under 1033(b).
a.    1033(b)(1) provides that if the property is converted directly into qualified replacement  property, the B of the property received is the same as that of the property converted, decreased by the amount of any money received that was not expended in acquiring the replacement property, and increased by the amount of any gain recognized or decreased by the amount of loss recognized.  P. 401 for example
b.    1033(b)(2), the B of the property acquired by purchase, following a 1033(a) conversion into cash or other property , equals the cost of the new replacement property, decreased by the amount of realized gain not recognized.
i.    if two or more replacement properties are purchased, the total B must be allocated amount the properties in proportion to their respective replacement cost. see p. 401 for example
6.    Liant Record v. Commissioner (1962)
a.    Test: there is a single test to be applied to both users and investors, i.e., a comparison of the services or uses of the original and replacement properties to the taxpayer-owner.
i.    example: if the taxpayer is an owner and uses the condemned land for one purpose and the replacement property for another that is not ok, where as if the taxpayer is a leasor and leases the condemned property for one purpose and the replacement property for another, that is ok?
1.    Ascher does not seem to buy this argument much
7.    Rev. Ruling 76-319:  is a bit embarrassing in its seriousness, a bowling alley with a lounge is not the same as a pool hall with a lounge; what assholes
8.    there are difference b/w 1031 and 1033:
a.    first difference: 1033 can involve cash outs
b.    second difference: 1033 non-recognizes gain only
c.    third difference: 1033, the cash out if not mandatory