patersons downgrade azz to "hold", page-6

Hi Sushi

I'm not going to pretend to be a US Tax accountant but I assume that mutiple levels of due dilligence would have been undertaken by each party AND that specialist tax advice would have been received.

This is what Wiki says.

" Section 1031(a) of the Internal Revenue Code (26 U.S.C. 1031) states the recognition rules for realized gains (or losses) that arise as a result of an exchange of like-kind property held for productive use in trade or business or for investment. It states that none of the realized gain or loss will be recognized at the time of the exchange.

It also states that the property to be exchanged must be identified within 45 days, and received within 180 days.[1]

1031(b) states when like-kind property and boot can be received. The gain is recognized to the extent of boot received. "

On the basis of this I would assume that the company must identify the "like" properties (being O&G leases) within 45 days and that the purchase process must be completed within 180 days.

cheers