I need guidance with this Tax problem

QUESTION

Myles Dews is the sole owner of Cousin’s
BBQ, Inc. He and another party are
considering forming a partnership to buy an old building, renovate it, and then
move both his restaurant and the other party’s sports bar into it. Myles would like to make this investment;
however, he needs approximately $200,000 for his share of the buy-in of the
partnership that will purchase, renovate, and manage the building. Myles’ only large liquid asset is his
self-directed IRA which is currently valued at $225,000 and is invested in
stock and bonds. Myles wants to direct
the custodian to sell the securities and use the proceeds to invest in the new
building renovation partnership. What is the tax implication of this
proposal? You must support your answer
with Primary Sources (Sections of the Code and/or any Revenue Rulings Letters
dealing with this subject). Your
response should be in the form of a Tax File Memo as follows:Facts: (Problem Info
given above)Issue: Can an IRA invest in a partnership that owns and
operates a real estate investment?
What’s the tax implication of this proposal?
Conclusion:

 

ANSWER:

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