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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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