TAX PRO Q: Ordinary income vs. Cap Gains or 1031

[Ziad Almufti]

Hey all, 

I own a boutique glamping hotel. We bought the land in an LLC 18 months ago and immediately began construction.  We opened doors to guests just 4 months ago.  

Our intent going into it was to hold long term.  We now have decided we want to sell.  Question: would our proceeds be taxed as ordinary income, or capital gains?  I'm unsure if the 365 day clock started when we broke ground, or when we welcomed our first guest.  Further, would we legitimately qualify for a 1031?