Really depends on their age and what kind of return they want.  I think there is a greater chance real estate goes down over the short term future than up.  Would be nice to buy after it goes down not before.  If they aren't afraid of long term gains tax, plus they may get hit with the 4% obamacare tax, might be worth sitting on cash for a little while.  You can buy CRP properties with a good 8-10yrs left on the contracts and get around 3% return after land taxes are paid for.  Best safe interest on money like that I have seen is in the 1-1.5% range for jumbo CD's, which even with $1mil doesn't net you much of anything. 

I'd be curious how many right now would take say $1mil cash after taxes or 1031 $1.5-$2mil right now into real estate of any kind.  Obviously some of both would be best.