Assume that you are a CPA and a tax specialist. Your clients include Ale and Grains, Communication Skills Inc., an S corporation, and Gustav and Heidi Lager, a married couple who are shareholders and the operators of Ale and Grains. The S corporation has expanded to include 100 qualified shareholders this year. Gustav and Heidi have told you that they have just obtained a divorce. Both individuals will continue to operate Ale and Grains for the ownership group, and neither party plans to dispose of her or his ownership interest. They know that certain rules govern the number of shareholders allowed in an S corporation, but they tell you not to be concerned because only their mailing addresses will change. They refer to the doctrine of substance over form and how it fits this situation. Write a letter to Gustav, Heidi, and the other shareholders offering your advice. Refer to the AICPA Code of Professional Conduct and the Statements on Standards for Tax Services where necessary.

CHAPTER 13 Choice of Business Entity—General Tax and Nontax Factors/Formation 609 Reinforce