These short-term losses would eventually yield long-term capital gains when the hotel is sold, so this entity would attract investors looking for short-term losses and long-term capital appreciation. For the short-term losses to be attractive, however, they must be usable by the investors on their personal returns and not trapped at the business entity level. All these factors point inevitably to the use of either the limited partnership, LLC, or subchapter S corporation for the hotel building entity