Acct. 4530 UNG RESEARCH PROBLEM Peter Sleiman entered into a lease agreement with Blockbuster Video Inc. to purchase land, build a video rental store, and lease the property to Blockbuster. Sleiman formed an S corporation and assigned his rights under the lease to the corporation, REE, Inc. REE then obtained bank loans of approximately $1 million, pledging the property that the S corporation had purchased as collateral under the contract. Sleiman personally guaranteed the corporation's loans, but the banks never asked him for repayment. Does Sleiman get a $1 million step-up basis for the guaranteed loans? Please write a client letter and tax file memo for this problem. Do your research as if your client lived in Atlanta, Georgia. No more than I pase' Cart case Looke Judges opinon Partial list of research aids: 11ct. Selfe v. U.S., 86-1 USTC 79115, 75 AFTR2d 86-464,778 F.2d 769 (CA-11, 1985) Plantation Patterns, Inc. v. Comm., 72-2 USTC 99494, 29 AFTR2d 72-1408, 462 F.2d 712 (CA-5, 1972). Acct. 4530 UNG RESEARCH PROBLEM Peter Sleiman entered into a lease agreement with Blockbuster Video Inc. to purchase land, build a video rental store, and lease the property to Blockbuster. Sleiman formed an S corporation and assigned his rights under the lease to the corporation, REE, Inc. REE then obtained bank loans of approximately $1 million, pledging the property that the S corporation had purchased as collateral under the contract. Sleiman personally guaranteed the corporation's loans, but the banks never asked him for repayment. Does Sleiman get a $1 million step-up basis for the guaranteed loans? Please write a client letter and tax file memo for this problem. Do your research as if your client lived in Atlanta, Georgia. No more than I pase' Cart case Looke Judges opinon Partial list of research aids: 11ct. Selfe v. U.S., 86-1 USTC 79115, 75 AFTR2d 86-464,778 F.2d 769 (CA-11, 1985) Plantation Patterns, Inc. v. Comm., 72-2 USTC 99494, 29 AFTR2d 72-1408, 462 F.2d 712 (CA-5, 1972)