A prospective client comes to your accounting firm. They tell you that they had formed the corporation a few years ago to take advantage of the new top corporate tax rate of 21%,. As a high income individual, your prospective client is receiving a 16% reduction in tax rate by shifting the income in his real estate investment business to the corporate form (37% individual income rate compared to he 21% corporate tax rate). He has income from other sources, so he doesnt need to take any of his gains out of the company for his living expenses. He has cancer and only expects to live for a few more years and when he dies, he plans to give his children all of the stock in the corporation. In each of the first two years he had financial income of just under $250,000 but during 2020 he had financial income of $1,000,000. He has made no distributions from the corporation. You immediately spot a problem for your client. What is it? Explain.