I have a client who started building houses for a profit. He sold his first house last year in June and just put for sale his second house this month of July 2024. He is telling me that his real estate agent told him that he can use section 1031 so that no gains are recognized on the sale of his first house. 

Is this true? Can anyone help me because I read the instructions on form 8824 and I don't see how he can qualify to use section 1031.