Reference no: EM132646863
Problem - Shelly Zumaya (2220 East Hennepin Avenue, Minneapolis, MN 55413) is the president and sole shareholder of Kiwi Corporation (stock basis of $400,000). Incorporated in 2008, Kiwi Corporation's sole business has consisted of the purchase and resale of used farming equipment. In December 2017, Kiwi transferred its entire inventory (basis of $1,200,000) to Shelly in a transaction described by the parties as a sale. According to Shelly and collaborated by the minutes of the board of directors, the inventory was sold to her for the sum of $2,000,000, the fair market value of the inventory. The terms of the sale provided that Shelly would pay Kiwi Corporation the $2,000,000 at some future date. This debt obligation was not evidenced by a promissory note, and to date, Shelly has made no payments (principal or interest) on the obligation. The inventory transfer was not reported on Kiwi's 2017 tax return as either a sale or a distribution. After the transfer of the inventory to Shelly, Kiwi Corporation had no remaining assets and ceased to conduct any business. Kiwi did not formally liquidate under state law. On an audit of Kiwi Corporation's 2017 tax return, the IRS asserted that the transfer of inventory constituted a liquidation of Kiwi; as a result, the corporation recognized a gain on the liquidating distribution in the amount of $800,000 [$2,000,000 (fair market value) $ 2 1,200,000 (inventory basis)]. Further, because Kiwi Corporation is devoid of assets, the IRS assessed the entire tax liability against Shelly, based on transferee liability. Finally, the IRS assessed a tax due from Shelly for her gain recognized in the purported liquidating distribution. Shelly has contacted you regarding the IRS's determination. Prepare a letter to Shelly Zumaya and a memo for the file, documenting your research.
What was jake gardner trying to do
: If Jake Gardner was overpowered, what would likely happen to him? What was James Surlock trying to do? What was Jake Gardner trying to do?
|
What amount of gain each Olinto Corp shareholder recognize
: Olinto Corp., an accrual basis calendar year C corporation, What amount of gain should each Olinto Corp. shareholder recognize on the liquidating distribution
|
What gain does Krol have as a result of the distribution
: Krol Corp. distributed marketable securities in redemption of its stock in a complete liquidation. What gain does Krol have as a result of the distribution
|
Explain how is the concept of otherness explored
: Explain How is the concept of "otherness" explored in the short story. Make sure to talk about Twyla, Roberta and Maggie in your discussion.
|
Prepare a letter to Shelly Zumaya and a memo for the file
: Shelly has contacted you regarding the IRS's determination. Prepare a letter to Shelly Zumaya and a memo for the file, documenting your research
|
What should margaret rims do
: Describe how the flow of information throughout YERS affected the problem. What should Margaret Rims do? What should the board do?
|
What is the proper tax treatment for Tammy contribution
: In 2016, when Green had E & P of $320,000, What is the proper tax treatment for Tammy's contribution of Green Corporation preferred stock
|
Summarize the results of your research
: Carla Navarro, who has been assigned to you for preparation of the current year's tax return. Summarize the results of your research
|
List four characteristics about culture
: What attitudes do you have that stem from these values, and where did they originate? What role did they play (or could they have played) in the scenarios?
|