Treasury Notice 2020-23; this Notice provides an extension to July 15, 2020 for taxpayers whose 45-day identification period or 180-day exchange period fall between April 1, 2020, and July 14, 2020.

Likewise, taxpayers engaged in reverse exchanges whose 45th day to identify relinquished property or 180th day to un-park replacement property fall between April 1, 2020, and July 14, 2020, are granted an extension to July 15, 2020.

From our initial review and understanding on the Treasury Notice, we believe the following example is correct: 

Exchanger sells relinquished property on March 15, 2020.

Day 45 would normally be April 30, 2020.  The new date is now July 15, 2020.

Day 180 is unchanged at September 11, 2020.

We are continuing to study the Treasury Notice ( and will provide additional updates as we go through this process.

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