A broad anti-abuse rule allows the IRS to recast any transaction intended to achieve a tax result inconsistent with the purpose of the statute. In this case, the purpose of the statute is to encourage economic growth and investment in designated distressed communities. The regulations specifically address the desire to prevent “land banking” (hoarding land). I would argue that investors pursuing this practice might want to hoard for the purpose of selling to a QOF and not even hold the land long enough to qualify for benefits. The QOZ program was designed to foster new investment; thus, any machinations directed at obtaining QOF designation for pre-existing investments may be frowned upon and subject to challenge. Given the arbitrariness of provisions within the statue, abuse may be difficult to prove. I am not aware of any anti-abuse enforcement actions thus far in this new area of the tax law.