Tax Optimization

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2026 Tax Optimization Plan

Augusta Rule + broader deduction strategy for MVHP and Auxil. CPA-ready brief.

Last updated: May 3, 2026
Back to Projects Auxil Seed Prep Processor Analysis Eulada Audit

Executive summary

MVHP is an S-Corp with approximately 20 W-2 employees. That detail materially constrains the retirement strategy below (Solo 401(k) and aggressive Defined Benefit plays are off the table due to ERISA non-discrimination rules). The realistic combined annual benefit, additive to the strategies you already have in place, is in the $40K to $70K range for 2026, plus longer-term upside on Auxil (QSBS) that could be much larger at exit.

The load-bearing strategies become: Augusta Rule (the highest-ROI quick win at $22-26K), Section 179 on Michael's new truck purchase, Montana PTET election, and Donor-Advised Fund optimization on charitable giving. Retirement-side, a 401(k) Safe Harbor plan is the realistic option but requires running the cost-benefit on employer matching for ~20 employees. Auxil's R&D credit is too small to chase in 2026 (no payroll, no contractors), but QSBS via Stripe Atlas C-Corp conversion is the real long-tail Auxil play.

This page is the brief to walk into the Jordahl & Sliter conversation with. Each section ends with the specific question to ask them so the meeting is short and decisive.

Already captured (baseline)
$15-25K
Escalade + MT Endowment + 529 + IRA
New 2026 deductions to add
$40-70K
Augusta + truck + PTET + DAF + Safe Harbor
QSBS upside (Auxil exit, long-tail)
Up to $10M
Excluded gain after 5-year hold

What you're already doing (baseline)

This brief is additive to what you already have in place. Confirmed in-place strategies as of May 2026:

✓ Escalade business-use deduction. Confirmed already deducting. Recommendation: verify with Jordahl & Sliter that business-use percentage is being documented annually with a current mileage log (MileIQ or similar). Audit defense lives in the log.
✓ IRA maximums. Both Nicki and Michael max their IRAs. 2026 limit: $7K each, $8K if 50+. This is the floor, not the ceiling, for retirement shelter.
✓ 529 College Savings Plans for Cooper and Logan. Established. Federal contributions are post-tax, but Montana offers a state deduction up to $3K per person ($6K joint) per beneficiary annually. With two beneficiaries, that is up to $12K joint of state deduction. Confirm with CPA that contributions are being captured for the MT deduction.
✓ Montana Endowment Tax Credit, $15K annual gift. Generates a 40% MT state tax credit, capped at $10K per individual or $20K per couple. Your $15K gift produces a $6K credit (under cap). If charitable budget allows, increasing the gift to $50K joint would max the $20K credit cap. Worth a conversation with the endowment about whether a step-up makes sense for both sides.

Priority 1: Augusta Rule (IRC §280A(g))

What it is, in plain English

You can rent your personal residence to a business you own for up to 14 days per calendar year. The rental income is tax-free to you personally (literally not reported on your 1040 under §280A(g)). The business pays the rent and deducts it as an ordinary business expense. Net effect: cash moves from MVHP into your pocket, MVHP gets a deduction, you owe no federal income tax on the receipt.

Why it works (legal authority)

  • IRC §280A(g) explicitly carves out short-term residential rental income from gross income reporting if the dwelling is used as a residence and rented for fewer than 15 days in the year.
  • The same code section allows the renting party (your business) to deduct the rental as a business expense, provided the rental is at fair market value and the use is for legitimate business purposes.
  • Tax Court precedent (Sinopoli v. Commissioner, 2023 and others) has tested the boundaries. Wins go to taxpayers with strong documentation. Losses go to taxpayers with sham documentation.

Defending the Whitefish property fair market rental rate

Your home is 7,000 sq ft on 47 acres in Whitefish. For corporate retreat rental purposes, you need a defensible daily rate backed by comparable rentals. Here is the comp picture:

Comparable tier Season Nightly rate Source / notes
Whitefish luxury VRBO/Airbnb (5,000+ sq ft)Shoulder (May, Oct, Nov)$2,500-4,000VRBO + Airbnb listings, 2024-2026 sampling
Whitefish luxury VRBO/Airbnb (5,000+ sq ft)Peak (Jul-Aug, Dec-Mar ski)$5,000-8,000Same source, peak demand pricing
Whitefish estate-tier (7,000+ sq ft, acreage)Peak ski$6,000-10,000Iron Horse, Lakeshore, Whitefish Mountain Estates listings
Corporate retreat premiumYear-round+20-40% over STRIndustry rule of thumb for commercial vs personal use
Defensible rate: $4,500/day. This is conservative-aggressive. It sits above shoulder-season STR pricing, below peak-season pricing, and reflects the corporate-retreat use case (which is what this is). Some comparable Whitefish estates rent for materially more during peak ski season, so $4,500 is not at the ceiling. The CPA should validate against current comps at filing time, but $4,500 is well within defensible territory for an estate of this caliber.

The math

ScenarioDaysDay rateGross to you (tax-free)After-tax savings*
Conservative14$3,000$42,000~$15,000
Recommended14$4,500$63,000~$22,000-26,000
Aggressive (peak comps only)14$6,000$84,000~$30,000-35,000

*Assumes federal marginal 32-37% + Montana 6.75% on the deducted rent. Actual depends on entity structure (S-Corp pass-through vs C-Corp).

Documentation requirements (this is the audit defense)

Augusta Rule audits exist. Wins require paper. For each rental day, build and keep:

  • Written rental agreement between Nicki/Michael (as homeowners) and MVHP (as tenant). Spells out date, daily rate, scope of use, payment terms.
  • 3+ comparable rental quotes from VRBO, Airbnb, or corporate retreat brokers. Print, date-stamp, file. This is the FMV defense.
  • Real board meeting agenda for that day. Substantive business topics (revenue plan, vendor strategy, succession, hiring, capital plan), not pretextual.
  • Real meeting minutes documenting decisions made. Not "we discussed things." Specific resolutions.
  • Attendees: officers and directors (Nicki + Michael minimum). Outside advisors are fine. No kids. No friends.
  • Payment from MVHP to Nicki/Michael via business check or ACH, NOT cash, NOT a journal entry.
  • 1099-MISC NOT issued. The income is exempt under §280A(g), so no 1099 is required (and issuing one creates reporting confusion).
  • Bank statement showing the deposit on the personal side.
  • Keep all records 7 years minimum.
What an audit looks like. The IRS will look for sham. Was it a real meeting? Was the rate reasonable? Did real business get done? They are not anti-Augusta, they are anti-bullshit-Augusta. If your paper trail shows a real board acting on real decisions at a defensible rate, you win. If it shows family dinner labeled "board meeting" at $10K/night, you lose.

Common mistakes to avoid

  • Renting at obviously inflated rate without market comps to back it up.
  • "Meeting" with no agenda or minutes.
  • Family-only attendees with no defined business role.
  • Booking all 14 days in one block with no business reason for the cluster.
  • Mixing personal use into the rental day (e.g., friends over for dinner during a "rented" day).
  • Charging round numbers that suggest pulled-from-thin-air pricing ($5,000 flat looks worse than $4,750 backed by comps).

Suggested annual cadence

Spread the 14 days across the year so each one has a real business reason:

  • Q1 board meeting: 2 days (annual planning, prior year close, capex plan).
  • Q2 board meeting: 2 days (mid-year review, hiring decisions).
  • Q3 board meeting: 2 days (Q4 prep, peak-season planning, vendor reviews).
  • Q4 board meeting: 2 days (year-end review, tax planning, next-year budget).
  • Strategic offsite planning: 2-4 days (long-range planning, brand strategy, succession, large initiatives).
  • Buffer: 0-2 unused days as audit cushion.

Ask Jordahl & Sliter

  • Confirm MVHP entity structure (S-Corp, C-Corp) supports §280A(g) rental deduction.
  • Recommend a rental agreement template (or provide one for you to use).
  • Validate the $4,500/day rate or recommend a different defensible figure.
  • Confirm payment mechanism: business check, ACH, journal-entry-and-distribute, etc.
  • Set up the bookkeeping coding so the rental expense is properly categorized and the personal deposit is excluded from income.

Other 2026 deduction levers, ranked by ROI

Each lever below has a different qualification bar and a different effort level. Pursue the high-ROI low-effort ones first.

Important constraint on retirement strategy. MVHP has approximately 20 W-2 employees. ERISA non-discrimination rules mean owner-favoring retirement plans either disqualify entirely or require equivalent benefits to all employees. Below reflects the realistic options given that constraint. The big-shelter plays (Solo 401(k), aggressive cash balance DB) common in owner-only-businesses are not on the table here.

401(k) with Safe Harbor (recommended)

~$50K personal shelter
Effort: Medium (plan setup + annual admin) · Eligibility: Best fit for 20-employee S-Corp

This is the realistic retirement play for MVHP at its current size. A 401(k) Safe Harbor plan allows Nicki and Michael to max personal contributions ($23K each in 2026, $30.5K if 50+) without failing non-discrimination testing. Cost: a 3-4% safe harbor match for participating employees. For 20 employees with ~60% participation at $40K average comp, employer match cost is roughly $15-25K/year. In exchange you get ~$50K combined personal pre-tax shelter (more if 50+).

The cost-benefit is real but not slam-dunk: you spend roughly $15-25K to shelter ~$50K. The personal tax saved on $50K at your bracket (~32-37% federal + 6.75% MT) is roughly $20-22K. The employer match cost is a real expense to MVHP, but it is also a deduction. Net benefit depends on your actual numbers.

Ask CPA: Run the 401(k) Safe Harbor cost-benefit with current employee comp data. Compare a 3% non-elective vs 4% match design. Recommend a TPA (Guideline, Vestwell, Human Interest are common low-cost options for businesses your size).

SEP-IRA

Not recommended at 20 employees
Effort: Low (setup) · Eligibility: Eligible but not pencil-friendly

Technically available but requires equal % contribution to all eligible employees. If you contribute 25% of comp for yourself, you contribute 25% for all 20 employees. For ~$40K average employee comp, that is roughly $200K/year of employer cost to shelter ~$70K of your own income. The math doesn't work. Skip unless you want to be very generous with employee retirement (which you don't).

Defined Benefit Plan / Cash Balance Plan

Complex, usually not pencil at this scale
Effort: High (annual actuarial review) · Eligibility: Possible with cross-tested design

Same non-discrimination wall as SEP. Can be designed with cross-tested allocations to favor owners, but requires actuarial fees ($5-10K/year), still requires meaningful employee contributions, and only pencils if owner comp is very high relative to employee comp. For a 20-person S-Corp, usually not worth the complexity unless you want to commit to large, predictable retirement contributions for many years. Worth running with CPA only if you have a specific reason to want $100K+/year of additional shelter beyond a Safe Harbor 401(k).

Auxil-side Solo 401(k) (potentially)

If controlled-group rules don't aggregate
Effort: Low if eligible · Eligibility: Depends on controlled-group analysis

Auxil currently has no employees beyond Nicki (and possibly Michael). A Solo 401(k) is theoretically available on the Auxil side IF Auxil stays owner-only. BUT controlled-group rules under IRC §414(b)/(c) may aggregate MVHP and Auxil for ERISA non-discrimination testing if Nicki owns >80% of both. If they aggregate, MVHP's 20 employees count against Auxil too, which kills the Solo 401(k) eligibility. This is a question only your CPA can answer based on actual ownership percentages.

Ask CPA: Are MVHP and Auxil a controlled group for ERISA purposes? If not, what is the sheltering opportunity through an Auxil Solo 401(k)?

Stripe Atlas Delaware C-Corp conversion for Auxil + QSBS (§1202)

Up to $10M excluded gain
Effort: Medium (one-time conversion) · Eligibility: Convert before Auxil revenue ramps

Once Auxil is a Delaware C-Corp held for 5+ years, IRC §1202 (Qualified Small Business Stock) lets you exclude up to $10M of capital gains on sale, federal tax-free. This is the single biggest tax break in the code for founders. The clock starts when stock is issued, so the longer you wait to convert, the longer you wait to start the 5-year clock. Conversion timing matters.

Also: Delaware corporate law is preferred by virtually every institutional investor. Combined benefit makes the Stripe Atlas conversion a clear move.

Ask CPA + startup tax specialist: Conversion timing relative to first SAFE / priced round. Document fair market value at conversion. Make sure stock is "qualified" (active business, <$50M gross assets at issuance).

R&D Tax Credit (IRC §41) for Auxil development

$60-$300, revisit later
Effort: Not worth it for 2026 · Eligibility: Available but pool is too small to bother

The R&D credit needs three buckets to add up: wages of people doing qualified research, contract research costs, and supplies (cloud, API, infrastructure). Auxil currently has none of the first two. Nicki is not on Auxil's W-2 payroll yet, and "Big C" is Claude Desktop (an Anthropic tool subscription), not a billable contractor. That leaves only supplies: Anthropic API/subscription, DigitalOcean for Auxil, hosting; realistically $1K to $5K per year right now.

The Alternative Simplified Credit on a brand-new business is 6% of qualified spend in year 1. On a $1-5K pool, that is $60 to $300. The documentation overhead and Form 6765 filing cost more than the credit returns. Skip for 2026.

When this becomes worth chasing: the moment Nicki or Michael go on Auxil's W-2 payroll, OR Auxil hires a third-party developer, OR Auxil's infrastructure spend scales materially. Any of those expands the QRE pool significantly. Until then, defer.

The bigger Auxil tax play is QSBS, not R&D. Section 1202 via Stripe Atlas Delaware C-Corp conversion is where the seven-figure tax break lives for founders. Prioritize that conversation with the CPA over the R&D credit.

Ask CPA: Defer R&D credit analysis until Auxil has W-2 payroll. Confirm the deferral does not forfeit any year-1 election rights.

Section 179 / Bonus Depreciation on the Escalade ESV (already deducting)

Confirmed in place
Effort: Maintenance only · Status: Already capturing this annually

You are already deducting the Escalade for business use. The recommendation here is maintenance: verify with Jordahl & Sliter that the business-use percentage is being documented annually with a current mileage log, and that the §179 / bonus depreciation election was set up correctly at acquisition. The audit defense lives in the mileage log; if you do not have one currently running, start one (MileIQ, Everlance) so 2026 has solid contemporaneous records.

Ask CPA: Confirm Escalade depreciation schedule is on track. Verify business-use percentage for 2026. Recommend a mileage tracking method if not already in place.

Section 179 / Bonus Depreciation on Michael's new truck (2026 purchase)

$5-10K savings (new opportunity)
Effort: Low (vehicle choice + log) · Eligibility: GVWR > 6,000 lbs + >50% business use

Michael needs a new truck in 2026, which is a fresh first-year deduction opportunity. Vehicles with GVWR over 6,000 lbs qualify for accelerated depreciation. Most full-size trucks meet this: F-250 and up, Silverado 2500 and up, Ram 2500 and up, Tahoe, Suburban, Yukon, Sequoia, Tundra. Year-1 deduction can be $25K-$30K+ depending on vehicle price, business-use percentage, and bonus depreciation rules in effect for 2026 (currently 20% bonus, may change with legislation).

Tactical considerations: time the purchase based on bonus depreciation rules at the time. Document business use from day one (mileage log, named business driver, business-use insurance rider if applicable). Avoid sub-6,000-lb trucks (smaller F-150s in some configurations) which fall under the much smaller passenger-vehicle depreciation cap.

Ask CPA: What is the optimal purchase timing in 2026 to maximize §179 + bonus depreciation? Confirm GVWR > 6,000 lb on the specific truck Michael is considering. Confirm the deduction calculation given expected business-use percentage.

Montana Pass-Through Entity Tax (PTET) Election (highest priority no-employee-constraint play)

$5-15K savings
Effort: Low (election filing) · Eligibility: S-Corps and partnerships

This is the strongest remaining lever NOT constrained by employee count. The election allows MVHP (an S-Corp) to pay Montana state income tax at the entity level, federally deductible without the $10K SALT cap on Schedule A. For a $6-7M business with $1M+ of taxable income flowing to Nicki and Michael, the federal benefit can be $5-15K/year. This is a near-pure-win move requiring just an annual election filing. Should be the first thing confirmed in the CPA conversation.

Ask CPA: Confirm Montana PTET applicability for MVHP. File the election for 2026 if not already filed. Election deadline timing matters (typically by extended due date of return).

Charitable Donor-Advised Fund (DAF) with appreciated stock

$5-30K savings
Effort: Low (one-time DAF setup) · Eligibility: Have appreciated public stock

If you hold appreciated public stock, donate it to a Donor-Advised Fund (Fidelity Charitable, Schwab Charitable, Vanguard Charitable). You avoid the capital gains tax on the appreciation AND get a full FMV deduction. Strategy: bunch multiple years of charitable giving into one big DAF contribution year for itemization advantage, then grant out from the DAF over multiple years to your usual causes (Whitefish Band Boosters, Bulldog Booster Club, etc.). Especially powerful if Auxil eventually has a liquidity event and you have appreciated assets to redirect.

Ask CPA: Identify any appreciated public stock positions worth donating. Assess itemization vs standard deduction crossover for current year.

Augusta Rule for Auxil too (once revenue starts)

+$22-26K savings
Effort: Low (extension of MVHP setup) · Eligibility: Auxil must have real business purpose

Once Auxil is a real entity with revenue and a board, the same §280A(g) rule applies. You get another 14 days of tax-free home rental, this time deductible to Auxil. Effectively doubles the annual benefit (28 days total across both entities). Caveat: the meetings need to be defensibly Auxil-specific, not pretextual. Different agendas, different attendees if appropriate, different decisions.

Ask CPA: When Auxil reaches enough operational maturity (post-revenue, post-board), add it to the Augusta strategy. For 2026, MVHP only.

Cost Segregation Study (home office portion or commercial property)

$5-15K (deferral)
Effort: Medium (third-party study, $3-5K cost) · Eligibility: Owned real property used for business

A cost seg study reclassifies certain components of a building (carpet, fixtures, landscaping, electrical) from 27.5/39-year depreciation into 5/7/15-year accelerated buckets. For a home office in a $2M+ home, the accelerated depreciation can shift $20-40K of deductions into early years (tax deferral, not absolute savings). For commercial property, the benefit can be much larger.

Ask CPA: Whether a cost seg study makes sense given your specific properties. Most studies pay for themselves at >$500K basis.

Health Insurance Premium Deduction (S-Corp)

$3-8K savings
Effort: Low (payroll setup) · Eligibility: S-Corp 2%+ shareholder

MVHP is an S-Corp, so health insurance premiums for 2%+ shareholders (Nicki and Michael) can be deducted above-the-line. Requires specific payroll treatment: premiums are paid through the company, included in W-2 Box 1 wages, and then deducted personally on Schedule 1. Most CPAs handle this correctly but worth confirming since the savings are real every year.

Non-discrimination caveat (20-employee context): Health benefits offered to officers must be offered on equivalent terms to other eligible employees, OR structured as an HRA that meets safe harbor rules (QSEHRA or ICHRA). For MVHP at 20 employees, you almost certainly already offer some level of group health coverage to staff, in which case Nicki/Michael's premiums get the standard above-the-line treatment without additional complexity. The wrinkle is only if you DON'T offer employee health currently and want to claim the officer deduction, which would create a non-discrimination problem.

Ask CPA: Confirm current group health setup is optimized for the S-Corp shareholder deduction. Verify W-2 reporting and payroll coding.

Home Office Deduction

$2-5K savings
Effort: Low (one-time setup) · Eligibility: Dedicated office space, regular and exclusive use

If you have a dedicated home office space used regularly and exclusively for business, the home office portion of the property is deductible. With a 7,000 sq ft home, even 200-300 sq ft for office space is 3-4% of expenses (utilities, insurance, repairs, depreciation) deductible. Modest but free money once set up. Note: the simplified method ($5/sq ft, max 300 sq ft) caps at $1,500. The actual-expense method usually wins for a property of your size.

Ask CPA: Set up the actual-expense home office calculation. Confirm what counts as "regular and exclusive use" for audit defense.

Spousal Employment Optimization

Validation
Effort: Low (review only) · Eligibility: Michael already an officer

Michael is already an officer at MVHP per our file. Confirm his comp is reasonable for the work he does (audit defense), and that he has access to the same retirement plan structures Nicki does. Roth IRA / Roth 401(k) contributions on his side broaden the tax-shelter footprint.

Ask CPA: Review Michael's comp for reasonableness benchmark, confirm both spouses are maxing out applicable retirement plans.

2026 calendar: what to do when

WindowActions
Now (May 2026)Send this brief to Jordahl & Sliter. File Montana PTET election if not already filed. Set up Augusta Rule documentation framework. Draft rental agreement template. Pull comparable rental quotes and save them. Schedule first board meeting before end of Q2. Schedule Michael's new truck purchase planning conversation with CPA before pulling the trigger.
June 2026First Augusta Rule rental day (Q2 board meeting). MileIQ on both vehicles. Verify 2026 IRA contributions are on track to max by year end.
July-August 2026R&D credit eligibility analysis with CPA. Mid-year check-in on charitable giving and DAF setup if pursuing.
September 2026Q3 board meeting (Augusta day). Run 401(k) Safe Harbor analysis with CPA (sufficient lead time to set up for 2027 if it pencils). Begin Q4 tax planning conversations. Stripe Atlas conversion for Auxil if ready.
October 2026Q4 tax planning session with Jordahl & Sliter. Review YTD results and finalize year-end moves.
November-December 2026Final deadline for Michael's new truck purchase if doing it for 2026 deduction. Final 2 board meetings of the year (Augusta days). Final MT Endowment gift confirmation (and step-up if pursuing the $20K credit max). DAF charitable contributions before December 31. Final 529 contributions for the MT state deduction.
February-March 2027File 2026 return with all strategies in place. Augusta documentation organized and ready to defend.

The CPA brief: what to ask Jordahl & Sliter

Walk into the meeting with this list. Most of these are yes/no or "set it up" decisions, not deep analysis.

  1. File the Montana PTET election for 2026. Highest-priority quick win, no employee constraint.
  2. Set up Augusta Rule documentation framework for 2026. Rental agreement template, payment process, bookkeeping coding.
  3. Verify Escalade business-use mileage log is current. Same documentation will be required for Michael's new truck once purchased.
  4. Time Michael's new truck purchase to maximize 2026 §179 + bonus depreciation. Confirm GVWR > 6,000 lbs on the specific model under consideration.
  5. Run 401(k) Safe Harbor cost-benefit analysis: estimate match cost for current ~20 employees + Nicki/Michael personal max contribution. Compare 3% non-elective vs 4% match designs.
  6. Confirm whether MVHP and Auxil are a controlled group for ERISA purposes (affects whether an Auxil-side Solo 401(k) is feasible).
  7. Defer R&D credit analysis until Auxil has W-2 payroll. Confirm deferral does not forfeit any year-1 election rights.
  8. Walk through Stripe Atlas C-Corp conversion timing for Auxil + QSBS implications. Coordinate with startup tax specialist if needed.
  9. Confirm 529 contributions are being captured for the Montana state deduction ($3K per person, $6K joint per beneficiary annually, two beneficiaries = up to $12K joint).
  10. Confirm health insurance premium deduction is being claimed correctly via S-Corp shareholder treatment, with W-2 Box 1 reporting and Schedule 1 above-the-line deduction.
  11. Discuss home office deduction setup using actual-expense method.
  12. Discuss DAF setup for charitable bunching, especially if any appreciated public stock positions exist.
  13. Schedule a Q4 tax planning session in October or November 2026 to make any year-end moves.

Risk and audit notes

Augusta Rule audits exist but are rare when documentation is solid. Don't skip the paper trail. Don't delete old comp quotes. Don't write minutes after the fact.
Aggressive valuations raise flags. A $10K/day claim for an average house is asking for trouble. The $4,500/day defense for your property is conservative-aggressive given comparable Whitefish luxury rental rates. Don't push it past $6,000 without serious comp work.
Family-only "meetings" with no real business decisions are the #1 audit failure mode. Document SUBSTANCE over form. A perfectly-formatted minutes document for a fake meeting won't survive audit. Have real meetings about real things.
All these strategies require entity-level setup. Sole proprietor with no entity? Most of this doesn't apply. Confirm entity structures with CPA before relying on any of these.
Disclaimer. This is general tax strategy information based on publicly available US and Montana tax law as of May 2026, not formal tax advice. Tax law changes; rates, limits, and credits cited are 2026 estimates and should be verified with Jordahl & Sliter. Augusta Rule applicability requires entity structure verification. Estimated savings ranges are illustrative and depend on entity type, income, deductions, and your CPA's specific recommendations. Use this brief as the starting point for the CPA conversation, not the ending point.

Sources / reference

  • IRC §280A(g) (Augusta Rule) full text: uscode.house.gov
  • IRC §41 (R&D credit) full text: uscode.house.gov
  • IRC §179 (deduction limits) and §168(k) (bonus depreciation) details: IRS Pub 946
  • IRC §1202 (QSBS) eligibility: IRS Pub 550 and case law
  • Montana PTET: Montana Department of Revenue MT Form PTE
  • Sinopoli v. Commissioner T.C. Memo 2023-105 (Augusta Rule audit precedent)
  • Whitefish luxury rental comp data: VRBO, Airbnb, local STR brokers (Lakeshore, Iron Horse, Whitefish Mountain Estates listings, sampled May 2026)