We Found a Great Company That Saved Us a Lot of Time

I work so many hours every week. The thought of all the work that would need to be done to find a new place to live without any help did not seem very appealing. My wife is very busy with work and our children, so she was not looking forward to it either. She then saw a commercial on TV about a company that works as being a really good apartment finder for Nashville residents. We immediately knew that it would be something that we would be interested in. We both found ourselves hoping that the server would live up to our expectations and it did.

My wife is the one who called the company to ask them questions. The process seemed pretty simple up front.…

How to Develop into a Expert Property Builder – Element I

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In excess of the decades I’ experienced many of our builder learners talk to pertinent thoughts these types of as what measurement dwelling do I make what do I put in it where by do I make it? Searching back it’ simple for me to make these choices now, but when I to start with begun making in 1975 these have been demo and mistake scenarios. And my hindsight is crystal apparent. It’ extremely simple for me to appear back and see points I wished I experienced regarded when I to start with begun making. That’ what you’ likely to study in this post.

You’ study the professionals and cons of staying a speculative or spec builder (as opposed to a contract builder.) If you’ not acquainted with people phrases, a spec builder is a person who will choose a web-site, pick out a structure, make a dwelling and then sell it to a shopper. A contract builder is a builder that you use to make a dwelling for you. By the way, spec making is how I propose you start out fairly than making a dwelling for anyone else. I’ clarify why afterwards.

I’ start out by showing you how to be a person of the best spec builders in your place, even if you’ by no means before crafted a dwelling. I’ expand this information by talking about factors that are one of a kind to spec making. Subsequent I’ focus on factors that are one of a kind to contract making, and factors that pertain to equally spec and contract making.

A Phrase Of Warning

I want to pressure that when commencing your development organization, you ought to individual your organization from your private lifetime. In the early 70′ I was in real estate industrial product sales. I scarcely survived a important economic downturn. Practically all the things I owned was in my identify and most of it was repossessed. Had I regarded then what I know now, I’ have retained that significant dwelling, that Mercedes and that airplane.

In the development business there are many points that can materialize to you, some of which you have unquestionably no handle about. In accordance to the 2008 Yearly Report by the Countrywide Heart for Point out Courts, in 2007 Americans filed about ninety million lawsuits, far more than a 3rd of which have been civil situations. This does not consist of the volumes of lawful disputes that have been settled before a lawsuit was at any time filed. Dependent on the sheer range of lawful disputes that crop up, in and out of courtroom, a person could say that most Americans run the hazard of staying involved in a lawful dispute at some place in their life – for many individuals, far more than as soon as. This is in particular correct for people who do the job in professions with high lawsuit vulnerability these types of as medical practitioners, dentists and, yes, in particular builders! You should …

Ideas For Real Estate Agents – How to Dress For Success In Real Estate

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Is there these types of a issue as dressing for results any longer? Pretty much any organization or company made use of to have a dress code but Relaxed Fridays, authorized problems, and comfortable attitudes have minimized the enforcement or existence of dress codes.

The real estate marketplace is no exception to the shifting of dress codes and attire for results. Some brokerages made use of to have symbol-coloured jackets many others mandated satisfies for gentlemen and satisfies or attire for gals (gals’ trousers were not satisfactory). Now, these types of attire looks really outdated and almost comical.

Arguments that “qualified attire” conjures up self-assurance in purchasers still persist – and with some reason, in some real estate marketplaces. Locations where match-and-tie company attire is still suitable have a tendency to be desired in larger, cosmopolitan places and when performing with larger money / larger power purchasers.

What’ going on in your authentic estate sector?

Initially impressions – In some places, formal attire is suitable for a very first assembly while it may well be perceived as above-the-top rated or daunting in other places. A qualified impression specialist indicates that attire for each gentlemen and gals real estate agents need to mirror the preferences of their purchasers.

Clues for suitable attire

This is a variation on “Place, site, site.” What clues does your shopper / brokerage site propose? If your brokerage company does not have precise direction or limitations on attire, look at what your purchasers, peers, and your opponents in your location wear as attainable rules for your personal dress-for-results strategy.

Dressing for results with the get the job done is messy

There will be instances when an agent will have to stroll, climb, or crawl around filthy attributes. Property inspections are section of the company and you need to dress carefully, safely, and appropriately for these situation.

And there will also be instances when the really grubby agent will be called to meet up with with a shopper, ASAP. It may well not be attainable to transform or refresh you before the assembly but a quick rationalization and apology can go a lengthy way towards easing an awkward minute. Customers can be incredibly comprehending.

Gone also much …

Some attire conveys also substantially of an, “I’ alternatively be on holiday vacation,” mind-set. With couple of exceptions, T-shirts, flip-flops, and shorts are still seen with disfavor among the several enterprises, together with real estate. Substantial temperatures can certainly affect preference of attire at instances but particularly relaxed dresses and footwear can be also substantially (or small) for even the most comfortable office environment and shopper atmosphere.

Customers also react less favorably with agents whose design of hair, dresses and extras is also outdated and unkempt. Excessively flashy, provocative, or inadequate fitting dresses are inappropriate at any time.

The very best dressed you

Great grooming is companion to becoming very well dressed. You may well have been dashing about but get a minute to comb your hair, straighten your dresses, …

The ABCs of Tax Lien Investing

Are you interested in yields of 6 percent to 50 percent on your money, secured by a property tax lien against real estate?

Author Joel S. Moskowitz explains how investors can buy little known tax lien certificates that pay high yields in his book, “The 16 Percent Solution”

As a bonus, although the author warns it rarely happens, the investor might get kicky and foreclose on the property. However, he cautions that property owners usually redeem, so investors must be content with just high yields.

What is a tax lien certificate?

When a real estate owner does not pay their property taxes, 27 states and 1,152 cities and counties sell tax lien certificates to investors. The government gets its property tax money immediately. The investor buys a tax lien, which is then secured by the real estate.

Tax lien certificate yields vary according to state law. Arizona’s top rate is 16 percent, Florida pays as much as 18 percent, but in Michigan, the rate goes up to 50 percent in the second year. If the property owner doesn’t redeem the property from the investor by paying the back taxes plus the high interest rate, the investor gets the title and possession of the property.

New investors can start small, perhaps investing a few hundred or a few thousand dollars, and then buy more property tax lien certificates later. Although not all states are smart enough to offer tax certificates to speed up tax collections, after reading this book, they’ll learn why they should.

At the time of writing, States currently offering tax certificates include Alabama, Arizona, Colorado, Florida, Georgia, Illinois, Indiana, Iowa, Kentucky, Louisiana, Maryland, Massachusetts, Michigan, Mississippi Missouri, Nebraska, New Hampshire, New Jersey, New York, North Dakota, Oklahoma, Rhode Island, South Carolina, South Dakota, Vermont, West Virginia and Wyoming.

The book’s outstanding appendix lists the interest rates and state-by-state procedures. For real estate investors who want to earn high yields without physically managing property, this new book shows how to do so. It also explains the few pitfalls to avoid and how to buy die best certificates with the highest profit opportunities.

On my scale of one to 10, this excellent book rates a solid 10.…

What is Deed Grabbing? How to Get a Tax Sale Property Without Attending the Auction

If you are interested in or working in the real estate industry, you’ve probably heard the term “deed grabbing” at some point. Deed grabbing is the method of obtaining tax sale property without attending the auction – by approaching the owners of tax delinquent property just before they are about to permanently lose the property, and offering to buy their home for a fraction of its value.

The term “deed grabbing” was probably coined by the large tax property investing companies who buy these properties at tax auction. Deed grabbers and big tax property companies aren’t friends. Often, deed grabbers grab deeds right out from under these big tax sale companies, just before they are about to foreclose. They also call deed grabbers “deed pickers” and “bottom feeders.” The big tax companies, needless to say, are sore losers who don’t care much about the tax delinquent owner and mostly care about their bottom line.

Since there is still a year or so after the property has been “sold” at auction before the big tax investing company can foreclose (sold in quotes, because it isn’t really sold that day), this is the best time to approach the tax delinquent owners. At this point they much sell, and they know it. Many have already moved on at that point, and are happy to sign their deed over to a deed grabber just to avoid the big company getting it. You can grab deeds during this time for as little as a few hundred dollars

Often, deed grabbers are the last source of help for the delinquent owners, and without the deed grabber coming and buying their home for something, the owners would lose everything. It’s a win-win situation at that point. That’s how to get tax sale property without attending the auction while at the same time helping out the owner. Don’t let the fact that these big companies call you a “deed grabber” stop you. They can go eat paste!…

How to Raise Your Credit Score From 499 to 600

For many people who want to fix credit rating, It would be ideal to have a 700 credit score but if your FICA scores are lower than you may need to make some adjustments to the way you’ve been doing things.  A low report affects your ability to get a mortgage, buy a car, apply for a store account and just about everything else having to do with money.

If your FICO score is between 499 and 600, then here are some simple methods that allows you to fix your credit report.

  • Get a copy of your credit report with credit scores online.  If you’ve been denied a loan for any reason, the reports are free.  If not, they are free annually from each of the 3 credit bureaus.  If there are any mistakes report them to either Experian, TransUnion or Equifax, whichever one had the mistake.  Once you know the problem then it’s easier to make repairs.  If there is a low number, you can attach a letter that explains the circumstances such as losing your job or getting sick or whatever happened at the time.
  • Paying off all your bills on time or completely will move your numbers up, but not enough to move 100 or so points.  Making a payment when it is due and then another after it is due, will increase your score more rapidly since it is computed monthly.  So paying off more than your balance really helps.
  • Pay off the card with the highest interest rate first while making more than the minimum payment on the others.  Paying more than the minimum always increases your ratings.  This will also reduce the overall amount that you owe which also affects your score.
  • Reducing the amount you own on all of your loans or notes each month when compared to the overall amount of credit available to you will also improve your credit score.  If you always have 100% credit available like many people who pay off their cards every month, you can actually have a higher score if you say keep a balance of say 10% of the available credit.  Remember it’s a “credit” score not a cash score.
  • Sign up for your bank’s online bill payment program and make sure you pay more than the minimum on each credit card.  You will never be late and never worry about stamps or the mail getting picked up on time.  Most of it is done electronically.
  • If all else fails and your score is really low, then try to convince a relative with a good score to allow you to piggyback on their credit.  You will immediately see an increase in your score due to their mentoring, strong history of good credit and the opportunity for you to learn more about good credit ratings.

Credit scores are just one part of get a lower interest mortgage or credit card.  Other factors should be considered just as important.  Knowing as much as possible before you apply …

How to Buy a House For Back Taxes, Dirt Cheap, Without Competition

So you’re looking for a smarter way to buy a property, either to live in, or to invest in. Congratulations. If you’re reading this article, it means you’ve leapt out of the “thinking” phase and into the “doing” phase, and most people never make it that far. There are many deals to be had, if you’re willing to do a little research.

You’ve probably heard that tax foreclosure property is a great investment, and you haven’t been led astray; but now, you’re going to learn how to buy a house for back taxes, dirt cheap, without dealing with the headache of competition. If you’re looking for a cheap property to buy for yourself to live in, stay tuned as well- this technique will work even better if you’re not an investor!

Right now, throw out everything you’ve heard or read about tax sales. If you’re smart, you’re going to figure out quickly that you can’t compete with all the big companies that will be clamoring to bid against you at the sale. Tax sale, be it for deeds or liens, is not a place for the savvy investor in today’s market. There’s a much better way for you to buy a house for back taxes: from the tax delinquent owner himself.

Most people overlook this strategy, which is why you’ll find next to no competition. If you’ve ever tried buying directly from an owner in mortgage foreclosure, then you understand why this is so widely unappealing to failed mortgage foreclosure investors. Frequently you can’t get these owners to return your call for the life of you– and if you do get a deal, then you have to deal with mortgage, the second mortgage, the back bills, the back taxes; but when you buy a house for back taxes, it’s a different animal.

Why?

Because these houses almost never have a mortgage!

That’s right. The mortgage company takes care of any tax problems to avoid losing their interest in the property. So you’ll find almost all these houses are free of a mortgage, or they wouldn’t be up for tax sale in the first place.

Another thing that might seem counter-intuitive is that the owners will almost always return your calls, and when they do, they’re eager to make a deal with you to sell to you, and for dirt cheap, just to get the property out of their name! This is because, as you’ll see, many owners of these properties aren’t people who are down on their luck, and are losing their homes. They’re people who inherited property, or absentee landlords, who have had it with this economy, and actually let the property go to tax sale on purpose, just to get rid of it.

This gold mine of owners can be hard to find, making them great prospects, and you’ll be pleasantly surprised to find how many of these owners are ready to hand over their deed for a couple hundred dollars to you, just because they’d rather see …

Creating a Quiet and Restful Home

A home is many things. For many people, their home is a way to retreat from the world and relax. A long day at work can feel endless. Many homeowners want to walk through the door and feel relieved knowing they can shuck off the day’s cares and let go of stress with friends and family. Creating a home that exudes calm is a task that can be done by paying close attention to all parts of the house. This includes each window, the bedding, the kitchen area and all bathrooms. Every room in the home should contribute to a feeling peace and harmony. Any homeowner should be aware of easy ways to help them create this feel in areas of the home from the attic to the basement.

Regulating Light

Light makes a huge different in any home. A large puddle of light in the middle of the family room on a cold day can lift anyone’s spirits. Soft kitchen lighting at night when preparing a meal makes the kitchen a place to gather and enjoy. When it comes to light, it’s best to help regulate it carefully. For example, using window coverings as you’ll see if you hop over to this web-site, well helps make sure that the entire room has the amount of light the homeowner wants. A series of shutters that can be easily opened and closed allows for the blocking off of unwanted light or the creation of a space that is entirely full of beautiful, warm natural lighting.

Using Color

Another way of creating an elegant and restful space is through the use of color. Color is all around wherever people look. The right colors depend on each person’s personal preference. Some people love bright colors like vivid shades of green and purples. Other people find it better to use neutral colors in their home such as browns and shades of grey. Any color scheme should be carefully thought out. For a more relaxed and peaceful feel, look for a background of shades of white and paler colors. Painting a wall a soothing color such as pale pink or understated peach allows the room’s walls to retreat and makes it feel less walled in.

A Warmly Inviting Home

A warmly inviting home is a place that is fundamentally serene. A serene home is where the chaos of the outside world is kept at bay. Using techniques such painting the walls the right window coverings helps vastly facilitate the process of creating a warm home that is calm. Many homeowners want to have an oasis in their lives where they can let down their hair and avoid worry. It’s easier than ever to do this with the use of careful attention to varied home details. An understanding of the process of creating a home that allows for total relaxation can be done. Any homeowner should think about what they want from their home and how they can get it.

Hiring the Right Long-Distance Company Movers

A long-distance move of any kind can be highly stressful. This is particularly true of a long-distance move with a company. Company relocations require a lot of patience and attention to all aspects of the move. Any company preparing for a move must be prepared well in advance. Organization and mastery over the details are crucial for these types of moves. The same is true of any help that company officials choose to hire. Help is particularly vital for those company officials who may not know a specific area well. Even those officials who are fully aware of their local concerns are served with help from experienced moving company people who know how to manage the move and have done many company moves before. A thoughtful moving company can make any company move much easier and less stressful.

Before Leaving

Before leaving, packing is vitally important. Proper packing should be done in order to make it easy to unpack all necessary items once the move begins. In a long-distance move, this is necessary as the items will be on the move for a longer period of time than in other kinds of moves. Hiring a moving company that might be found if you hop over to this website can make packing easy. Many long-distance movers offer packing that companies need as well as moving services. Most companies opt for a gradual packing plan that allows them to plan for the move they have in mind in stages.

Planning For Transit

Moving items long distance can take many forms. Some companies prefer to move their items in trucks they own. Other companies like the convenience of having another company to provide transport for them. In many instances, a combination of both kinds of transport methods is best. Lighter items can be transported in light trucks because they don’t take up much space. Larger items with great heft are best fitted in a large truck where they can be securely fastened during all stages of the move. An effective and easy long distance move is one that allows these decisions to be made well in advance so there are no last minute decisions that must be made during the move.

Unpacking it All

Once the move has been planned and started, the next stage can begin. During this stage, the focus must be on making sure that all items are brought to the ideal space in each place. Each particular item must be carefully carried into the new space once it is unpacked from the truck. A good moving company can provide the long-distance mover with the opportunity to unpack right from the van and not worry that they need to spend even more time unpacking once at the final location. This can help any company owner save both time and money as the move flows more smoothly and easily. Advance planning and the right help are the keys to an effective and thoughtful long-distance move.

 …

How to Finance Seemingly Un-Financeable Properties in Real Estate Investing

Some houses or multi-family properties in real estate can seem un-financeable. This could be for a number of reasons including the perspective buyers or title issues with the properties. Unfortunately, these problems seem to occur after an investor buys a property and then can’t sell it.

Let’s examine the usual reasons that properties cannot be financed and what can be done. The most common issue is likely that the appraisal on a property isn’t sufficient to cover the costs and expenses of a rehab. The investor often only finds this out after he has completed the rehab and has a ready and willing buyer who has to get a conventional bank loan to buy it.

On this same vein, the appraisal may come in but the buyer can’t get financing because of more stringent lender requirements – such as credit scores, time on a job, recent foreclosure history or bankruptcy to mention a few. It may not be as simple as going on to another buyer or just getting another appraisal, especially if this buyer had been declined by FHA in the first place as the investor’s property is “tainted” as to appraisal in the FHA system for at least six months.

The simplest solution to the credit issue and appraisal issues is to get private lenders or portfolio lenders to finance the sale. Private lenders are individuals who are willing to loan money that they would normally have in a bank earning a couple of percent interest. The investor should offer this individual a 10% interest-only loan secured by a first mortgage on a property with a two or three year balloon note. This private lender could also receive 2% to 5% as closing points on the loan and have a pre-payment penalty of three months interest.

The following is an example of what the private lender would get on a $100,000 mortgage: The buyer should be able to put down 20% of the purchase price to secure the mortgage in case of a market decline. A lot of current home buyers have large deposits because they went through foreclosure and haven’t paid mortgage payments for extended periods. 10% interest on $100,000 = $833.33 per month versus perhaps $83.33 in a local bank at a 1% interest on a savings account.

At closing, the lender would get cash of $3,000 to $5,000 as closing points. If the homeowner refinanced during the term of the loan and paid the pre-payment penalty, the private lender would additionally receive $833.33 x 3 months pre-payment penalty = $2,500.

The appraisal should be done by a reputable appraiser and a title policy and insurance should be provided to the private lender. An attorney should draft all the mortgage documents and do the actual closing to protect the investor/seller and the lender.

Using a private lender allows a buyer with blemished credit to purchase a home. It also allows the seller to not have to be dependent on the whims of a local or national …

What Happens When a Property is Sold For Back Taxes?

When a property owners fails to pay their property taxes, they are usually given an ample period of time to rectify the situation – at least a year in most cases, and often many years. If they fail to make arrangements to pay the taxes, the government will sell the deed to their property at tax sale (or a lien on the property, in tax lien states) to the highest bidder at tax sale.

The winning bidder must pay the full amount of their bid in cash at the tax sale, and then must wait out the redemption period before they can foreclose and apply for the deed. During the time, the owner may still pay the back taxes and penalties as well as the interest on the winning bidder’s investment and bail the property out of taxes. Once the redemption period expires, the owner loses the property permanently.

For investors, this is not a great way to buy property. You aren’t allowed to inspect properties before bidding on them, so you don’t quite know what you’re getting into. And on nicer properties, owners frequently pay off the deed or lien. Not to mention that the competition at tax sale is fierce, and you’re often competing against large companies that invest in tax sale properties full-time. There are few deals to be had any more at tax sale, and to profit from the property you’ve really got to buy it outside the auction.

The best way to get back tax property is to wait until close to the end of the redemption period and then see who still hasn’t paid off their taxes. This is the prime time to contact these people, as they need to sell to keep from losing everything to the government. These owners are often ready to sign over the deed just to be done with the foreclosure and move on.

Also, by this time you can be fairly certain that the properties left are free and clear. Mortgage companies step in and pay off delinquent taxes to redeem properties (usually before the sale), and properties that make it that far are almost always mortgage free.

All this adds up to property that is almost guaranteed to have built-in profit at the time you buy – especially if you can grab the deeds for a few hundred dollars from owners that were going to let the property go anyway.…

Non Performing Loans Vs REO Bank Owned Property – How Do They Differ?

To make real estate investing work for you, you must always take into consideration economic conditions that dictate which type of real estate investment is the best choice at any given time. Do you know your basics? What are Bank Owned REO Properties or non performing loans? What is the difference between the two? It is quite simple really.

Both non-performing loans and Bank Owned REO Properties are the unfortunate children of economic fall down. As economic crisis takes swing so does losing homes as struggling homeowners cannot keep up with loans and mortgages.

An adaptation of the well know children rhyme “First comes a non performing loan then a foreclosure” does well to illustrate the progression of distressed property handling and the major difference between the two concepts. Whereas they undoubtedly trod the same road, the difference in how far along the road each is.

Say a homeowner cannot afford to pay a loan anymore. First month the bank lets it slide. The second month, they mail the letter. The third the gavel comes down – the property has been declared a non-performing loan. For all intents and purposes non-performing real estate loan is a property loan that has defaulted or is in danger of defaulting when homeowner cannot make payments any longer. With some exceptions, three months is all a homeowner has to turn over the dough before his loan is declared non-performing. And current economic conditions being as they are, non-performing loans are sprouting like mushrooms after rain. Financial corporations specializing in non performing loans will help with purchasing a loan that best fits individual financial portfolios. By liquidating involved assets they can realistically provide a good value. But not a 50% discounted price. Not with complementary property repairs. Not bulk. And certainly not without tons of paperwork and fees. None of the things Banks Owned REO can and will do to move the sale along.

Bank owned REO property, on the other hand, is the next step in the distressed property timeline. No payment on a property loan will sooner or later result in “walking the plank”, in other words the dreaded foreclosure. Foreclosure unceremoniously plunks down distressed property to the auction table. Properties that cannot be auctioned off it end up as Bank Owned REO Properties. With current economy banks have a veritable tsunami of real estate properties coming their way. Wildly scrambling to regains at least some money and clear the books, banks sell Bank Owned REO Properties like tomatoes on local market, at a discount, liens and other expenses on the home removed.

While both are viable options for a real estate investor, everyone wants to buy where a deal is better. And in real estate, affordable, bulk, plenty and flexible of Bank Owned REO is a far better than a sometimes, costly, and rigamarole non-performing loan.

And who wouldn’t go for a deal that will brings maximum profit on a minimum investment, fast.…

History of the 1031 Tax-Deferred Exchange in Real Estate

What is the history of the 1031 tax-deferred exchange? Some investors know that the exchange is a strategy long used by real estate investors. An investor sells investment property and buys or acquires “like-kind” property following the regulations and stipulations of Section 1031 in the Internal Revenue Code (IRC) to defer federal tax, capital gain, and depreciation recapture taxes. “Like-kind” is defined as any type of real estate. You can sell a retail center and buy an apartment building or land in a 1031 exchange; you can sell an office building and buy an industrial building or hotel.

Note: the 1031 tax-deferred exchange is often known as a deferred exchange, a “like-kind” exchange, a Starker exchange (you will see why later in this article), or it is often simply known “a 1031”. No matter what it is called, investors can defer the tax by reinvesting into another investment property if they follow the strict rules. It is one of the tax benefits of investment real estate ownership.

So how did this all come about – what is the history of the tax-deferred exchange?

The tax-deferred exchange actually has a rather long and complicated history dating back to 1921. The first income tax code was adopted in 1918 as part of The Revenue Act of 1918, but it did not provide for any type of tax-deferred exchange. The first tax-deferred exchange was authorized as part of The Revenue Act of 1921 when the United States Congress created Section 2021 of the Internal Revenue Code. Between 1921 and 1970, exchanges were always simultaneous swaps between two parties, by the way.

In 1928, the section number in the Code was changed from 2021 to Section 112(b)(1) with the passage of The Revenue Act of 1928. The 1954 amendment of the Tax Code changed it again, this time to Section 1031 of the Internal Revenue Code, and much of our present language and procedural details were adopted at that time.

However, we can thank the Starker family for the rise of the “deferred exchange”, the way a majority of exchanges are handled today (as opposed to simultaneous swaps). In 1979, a taxpayer named T.J. Starker, transferred timber property (which was free and clear of debt) to Crown Zellerback Corporation in exchange for a promise by Crown to transfer to him like-kind property chosen during a five-year period. At the end of this five-year period, Mr. Starker would receive any outstanding balance in cash. A trust agreement was formed so that all sale proceeds were held in a separate bank account, and clear terms of the trust stated that the funds could only be used to purchase replacement property for the Starker family, and for no other purpose. In fact neither Crown nor Starker even had access to the money except for buying replacement investments. The IRS, upon seeing the arrangement, denier the tax deferral arguing that a 1031 mean a simultaneous swap, which was how the IRS interpreted the code to this time. In …