Research Assignment

Buffalo Bill purchased a 5,000 acre ranch in Montana. He tried unsuccessfully for 15 years to raise buffalo and to sell buffalo meat to a chain of health food stores. He offered the ranch for sale, but was unable to find a suitable buyer because of the size of the property. He decided to market the property in 50 parcels, each approximately 100 acres, to hunting enthusiasts as private game reserves. He advertised in magazines read by hunters and outdoor enthusiasts. During the current year, Mr. Bill was able to sell 10 parcels at a net profit of $400,000. He would like you advice regarding the proper tax treatment of this gain (capital, 1231, or ordinary). He is concerned about the fact that he is selling it off in a number of parcels rather than one property. Write a client letter to Mr. Bill regarding this matter. A sample of a client letter is found in Chapter 2 Exhibit 2-10 of the textbook.