The article offers updates to a tax code decision in Ocmulgee Fields Inc. case where the taxpayer's arguments and inferences were examined to draw the decision in the U.S. The court's decision says that a like-kind exchange was disallowed because it was structured to avoid the purpose of Code that governs exchanges between related persons. Moreover, it notes that the court's decision reinforces strict compliance of tax code such as the Code Section 1031(f).