An S Corp is a tax entity type that has no place in the legal world.An LLC can be taxed as a disregarded entity, partnership, S Corp, or C Corp depending on the number of members and elections made.

If that is not the case then disregard my comments.

This entity would also be the/a general partner in syndicated deals.HoldCo: A WY manager-managed LLC with initial nominee manager (for anonymity), disregarded for tax purposes.

The IRS stated that an individual transferring replacement properties to a limited liability company (LLC) treated as a disregarded entity (i.e., sole proprietorship) does not violate the Section 1031(a)(1) requirement that the property be used in a trade or business or held for investment. 

An LLC is a disregarded entity for tax purposes so it does not offer the kind of help he would be looking for.

But when multiple forces start to align we disregard the signs at our own peril. 

It can be a partnership within an LLC shell, but cannot be a single-member disregarded entity. 

I think the question came down to whether a single member LLC that is a disregarded entity is considered a business for tax purposes or not.

They are state structures.An LLC can be taxed as a partnership, a C Corp, an S Corp or totally disregarded.Most LLC structured for buy and hold real estate are usually either taxed as partnership or disregarded entity.

Okay disregard.