Are you suggesting disparate treatment would have to be proven? 

Real estate that qualifies for 1031 treatment (tax deferral) is any type of real estate you hold with investment intent. 

The first treatment was the worst.

The second gives you both tax deferred treatment in a 1031.  

@Sheri Fluellen, As several have alluded to a membership position in an LP will not qualify for 1031 treatment. 

Now, we only opened one account for the SLLC, not multiples - for all I understand and was advised by our asspro lawyer, the requirement is for clear accounting/bookkeeping (being able to account separately for each children Series-LLC and/or asset), not for a bank account for each of the childrens SLLC.I was not aware of any special treatment of SLLC from banks....but I did experience vastly different responses from bankers and loan officers based on the question asked and their domain of expertise (or ignorance) on various other subjects before...so, if you don't find the solution to your problem, change the person you ask or reformulate the question...might be surprised how many "professionals" know only their small yard for answers and tell you is not possible.

when you split and dissolve the partnership, and deed a property into a new entity that only you own, and you go to sell in let's say 3 months..well you've owned it total for 14 months, but only 3 months under this new entity without your partner...would that qualify for long term or short term capital gains treatment?

All say that spot treatment works if you can identify the colonies.

The LLC is the investment of the IRA, thus the difference in treatment as compared to administrative expenses of the IRA proper.

the loan proceeds are traced to determine tax treatment and potential deductiblity.