You can draw on basically anything relevant. If it's material to the analysis, it's fair game. It's just a question of what you believe would persuade the IRS personnel making the decision as to whether the 50% requirement is satisfied.
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What can be included in the “facts and circumstances” provision for unique situations when it comes to fulfilling the 50% test for a QOZB?
Also, what constitutes a unique situation?
Answers
If your business cannot meet any of the three alternative test to compute gross income (service hours, compensation and management and property location), you may still meet if, based on all your facts and circumstances, you can support the 50% gross income test. It might be a combination of all the above, plus other circumstances.
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