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30 PROBATE& PROPERTY JULY/AUGUST 2005 Related Party Exchanges— An Exchange Enigma By Nancy N. GrekinPROBATE& PROPERTY JULY/AUGUST 2005 31 istic difference between the two types of transactions must, at least on an occasion, engender different results. Barker v. Commission, 74 T.C. 555, 561 (1980) (citations omitted). Adopted in 1989, Code § 1031(f) is the most recent amendment to Code § 1031, imposing special restrictions on exchanges between related parties. Following this amendment, the Tax...