Glen Zucker is opening a new trendy restaurant in the Calabasas shopping center. He owns a self-directed Individual Retirement Account (“IRA”) and would like to liquidate stocks from his IRA and use up to $300,000 from his IRA account to have the IRA invest in the new restaurant business. What are the tax implications if an IRA invests in a partnership that owns and operates a restaurant? Please cite administrative regulation, ruling or court case.