Prepare a short memo

Over the years, Julie Hoyle (117 Western Avenue, Peoria, IL 61604) has taken great pride in her ability to spot exceptional rental real estate investments, particularly in terms of their appreciation potential. As a result, she has accumulated several properties. In the past, she was able to devote only a limited amount of time to these ventures. In the current year, however, she retires from her full-time job and devotes most of her time to the management and operation of the rental activities. The relevant tax attributes of each of Julie’s properties are as follows: Julie has enough understanding of the tax law to know that she is a qualifying real estate professional for the current year and materially participates in all three properties within the meaning of § 469(c)(7). However, she is uncertain whether she should treat the properties as three separate activities or aggregate them as one activity. Write a letter to Julie to assist her in making the decision. Because of Julie’s expertise in the tax law, feel free to use technical language in your letter. Scan several publications that are read by owners of small businesses. Some of the articles in these publications address tax-related issues such as how to structure a new business.

Do these articles do an adequate job of conveying the benefits of issuing § 1244 small business stock?

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Prepare a short memo explaining the use of § 1244 stock and post it to a newsgroup that is frequented by inventors, engineers, and others involved in startup corporations.

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