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§121 applies to the gain whether ordinary or capital.

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Interesting. Do you know what the effects are on the Section 121 exclusion? While I've never used the strategy, I've seen a lot of chatter online about selling your home to your LLC or S Corp if you're going to rent it out. Would Section 1239 change the nature of the gain so it could not be excluded? Or would it only apply to the gain after the exclusion? I'm guessing it's the latter or the strategy would make zero sense.

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