A Smarter Alternative to the Drop-and-Swap? Understanding Revenue Rulings 99-5 & 99-6. Can you use a 1031 exchange to buy into or buy out an LLC that owns real estate? Surprisingly, under certain IRS rulings, the answer may be yes. Revenue Rulings 99-5 and 99-6 create little-known planning opportunities involving LLCs, partnership interests, and investment properties — but the rules are highly technical and mistakes can be extremely costly. In this article, we break down how these strategies work, common pitfalls involving family partnerships and related-party rules, and why careful planning is essential for Newport Beach and Costa Mesa real estate investors navigating LLC ownership, 1031 exchanges, and capital gains planning.








