Research Problem 3. Your client, Alternate Fuel, Inc. (a regular corporation), owns three sandwich shops in the Philadelphia area. In 2013, the year Alternate Fuel incor- porated, 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 2015, 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 2016. The land has appreciated substantially in value, and the company could use the cash infusion. Given that the land has not been used in the business, will any gain realized be categorized as a § 1231 gain or as a long-term capital gain? Explain.

Using Research Problem 3 found on page 14-64 in the textbook, prepare a memo to the tax research file for Alternate Fuel, Inc., discussing your analysis of the gain