Under the taxpayer-use test for a § 1033 involuntary conversion, the taxpayer has less flexibility in qualifying replacement property than under the functional-use test.

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Under the taxpayer-use test, the taxpayer has more flexibility in qualifying replacement property compared to the functional-use test, which requires the replacement property to be functionally similar to the converted property.

Under the Taxpayer-Use Test for a § 1033 Involuntary Conversion