Question: Your client, Alternate Fuel, Inc. (a regular corporation), owns three sandwich shops in the Philadelphia area. In 2011, the year Alternate Fuel incorporated, it acquired

Your client, Alternate Fuel, Inc. (a regular corporation), owns three sandwich shops in the Philadelphia area. In 2011, the year Alternate Fuel incorporated, it acquired land on the outskirts of Philadelphia with the hope of someday farming the land, to cultivate humanely harvested meat and grow organic fruits and vegetables to use in its sandwich shops. In 2013, Alternate Fuel drew up plans for the farm and began consulting with agricultural experts about the best locations for crops and the number of animals that could be sustained on the acreage. After reviewing those plans, Alternate Fuel's CEO decided that the plans are not currently financially feasible and would like to sell the land in 2014. The land has appreciated substantially in value, and the company could use the cash infusion. Given that the land has not actually been used in the business, will any gain realized be categorized as a ยง 1231 gain or as a long-term capital gain?

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