The cases I've heard about were all two-step processes. 1) create a company to own the real estate 2) invest in the company in the IRA. My parents did something like this, though it was with a group for a real estate development deal. It was a paperwork nightmare, I think, and mom just took all of it out last year as her RMD + penalty withdrawal (she's in her 70s) to simplify things. Though a lot of that is because the actual deal hasn't gone anywhere. The shareholders had to sue the organizer, so she had a ton of "on paper" money that wasn't likely to ever be worth anything increasing her RMD every year.