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ownership interest in the newly formed RIC by paying between $1
and $3 million for stock and, as sole shareholder, votes to
approve the initial management contract. These costs are similar
to organizational expenditures of a corporation15 or partnership
15Sec. 1.248-1(b)(2), Income Tax Regs., provides the
following examples of corporate organizational expenditures:
legal services incident to the organization of the
corporation, such as drafting the corporate charter,
by-laws, minutes or organizational meetings, terms of
original stock certificates, and the like; necessary
accounting services; expenses of temporary directors
and of organizational meetings of directors or
stockholders; and fees paid to State of incorporation.
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