You're welcome to provide a link that reinforces your statement.(2) I'm much less concerned about what position the IRS takes than what position my clients can support under authoritative guidance. 

Intel will be even longer because of the sheer size, it'll house 8 chip factories and additional supporting operations over 2,000+ acres.

Estimating a project is time consuming and hard to get a hold of contractors that do this the proper way. 

Make sure the market you choose supports this strategy.

Memphis holds unlimited opportunities.

If STR regulations come to the area, my plan is to do MTR and while it is not as much revenue as STR, I should be able to generate a decent return over a 5 year minimum hold. 

As I'm sure you know, especially when you're getting started out, having the right team members in place will help to round out any knowledge/experience items that you may need support on.

Whether or not you support STR regulations, I think this is far from over.

Continue to ramp up and I prefer to own long term holds in areas where they appreciate.

(b) That supports improvements that may be constructed above the lands.