rev_proc · Rev. Proc. 2002-22

Revenue Procedure 2002-22

Sets forth the IRS's position on undivided fractional interests in real property and the conditions under which they will not be treated as an interest in a business entity — foundational for tenant-in-common (TIC) structures.

Key takeaways

  • 15 conditions for TIC treatment.
  • Distinguishes TIC interests from partnership interests.
  • Often referenced in DST/TIC educational discussions.
Educational information only. The content on this page is general education and is not tax, legal, accounting, or investment advice. Consult your own CPA, attorney, and licensed investment professionals before making any decision related to a 1031 exchange or Delaware Statutory Trust.