old and cold rule
n.— «If you plan to use the vacation home as the relinquished property, do not use it personally for at least two years, and two tax returns. The IRS has adopted what is known as the “old and cold” rule. If you engage in a transaction for the purpose of avoiding the payment of tax, and the transaction occurred more than two years ago, the IRS will generally not pursue the matter.» —“Housing Counsel: IRS Monitoring Starker Exchange” by Benny L. Kass Realty Times May 1, 2006. (source: Double-Tongued Dictionary)