Our client owned his Relinquished Property in the name of a two member, Limited Liability Company (LLC) and wanted to acquire its new property in the name of just one of the members of the LLC. This poses a problem for the Exchange because the identity of the taxpayer MUST be the same in the Replacement Property as it is in the Relinquished Property. If the members are going their separate ways, get the property deeded out of the LLC before attempting the Exchange. Do this well before the sales agreement is entered into.