Six Nevada LLC InvestCo SPVs ($15M each) acquire, pro rata, 99% of the membership interests of a single HoldCo that holds 12-month, single-user subscriptions (120,000; 20,000 per SPV) to KureAI's AI-enabled genomic intelligence platform. At the Manager's discretion the HoldCo or SPVs donate the subscriptions to a government entity or public charity, seeking a charitable deduction for Investors based on appraised FMV. If a donation cannot be completed, the Manager may pursue retail sales of the subscriptions (Sale Option). Investors have no vote on the option chosen; the report flags significant IRS audit, valuation and inventory-classification risk.