solved 1-Betty Haley and Jerry Filpi have lived together for over

1-Betty Haley and Jerry Filpi have lived together for over 3 years. They are not married but tend to pool their money to pay bills, buy groceries, etc. Thinking of a better life, Betty used the pooled funds to buy a lottery ticket and won $4.2 million. The lottery commission told them the payout could be to only one person, so they executed a “separate ownership agreement” which provided an equal interest for each of them in the ticket. Will Betty be required to pay gift tax on the transfer of a one-half interest in the ticket to Frank? Your solution should be based on a Letter Ruling or TAM which should be cited in your response.2- Eyvette operates Henry Auto Parts as a sole proprietorship. The business is growing due to maintaining a large inventory of quality parts that are reasonably priced. She is outgrowing her current warehouse which she leases from State Street, LLC. State Street, LLC was formed about ten years ago and is owned by two sisters who are heavily invested in real estate. Eyvette’s lease ends in seven months and she is ready to take on a larger warehouse space. After meeting with her investment advisor, she is considering buying a building. Leasing has its benefits but also many drawbacks. Investing in real estate is very appealing to her – equity growth and no landlord sounds appealing. Eyvette finds a suitable building for $1.0 million. After meeting with the bank, she learns that a down payment of $250,000 will be required. The balance can be financed. Her problem is that the only place she has that kind of cash is in her self-directed IRA. She doesn’t want to take a distribution because of the tax and penalties (she is 55 years old), so she is considering acquiring the building inside her IRA. Then her business could be the sole tenant and pay rent to her IRA. Sounds perfect! However, her financial advisor told her there might be problems with her IRA acquiring this type of asset, so she was referred to you. Would you advise Eyvette to buy the building in her IRA and then rent it as the sole tenant? Your conclusion should cite the relevant IRC Section(s) and any other sources you think are applicable