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Boots, Inc. is owned equally by Frank Albert and his daughter Nancy, each of whom hold 1,000 shares in the company. Frank wants to retire
Boots, Inc. is owned equally by Frank Albert and his daughter Nancy, each of whom hold 1,000 shares in the company. Frank wants to retire from the company, and it was decided that the company will redeem all 1,000 of his shares for $25,000 per share on December 31 of this year. Nancy would like to have Frank stay on as a consultant after all of his shares are redeemed. She would pay him a modest amount of $500 per month. Nancy wants to know if there is any de minimis rule such that Frank would not be treated as having retained a prohibited interest in the company because he is receiving such a small amount of money. The purpose of this exercise is to get you familiar with what court cases look like, related to a topic we are studying. This question is not meant to be a full-fledged research project by any means. I do not expect you to read the entirety of these court cases - they are very long! Skim the following two court cases using the two links provided: Lynch v. Commr, 801 F.2d 1176 (9th Cir. 1986), reversing 83 TC 597 (1984), Seda, 82 TC 484 (1984), and Cerone, 87 TC 1 (1986). At a minimum, read what the case pertains to on the first page of each case, read approximately two paragraphs before the conclusion section (Section IV), and read the conclusion section. Based on the court cases, please write a paragraph (at least four complete sentences) to provide an answer to Nancy's question. Please use correct grammar and spelling. Boots, Inc. is owned equally by Frank Albert and his daughter Nancy, each of whom hold 1,000 shares in the company. Frank wants to retire from the company, and it was decided that the company will redeem all 1,000 of his shares for $25,000 per share on December 31 of this year. Nancy would like to have Frank stay on as a consultant after all of his shares are redeemed. She would pay him a modest amount of $500 per month. Nancy wants to know if there is any de minimis rule such that Frank would not be treated as having retained a prohibited interest in the company because he is receiving such a small amount of money. The purpose of this exercise is to get you familiar with what court cases look like, related to a topic we are studying. This question is not meant to be a full-fledged research project by any means. I do not expect you to read the entirety of these court cases - they are very long! Skim the following two court cases using the two links provided: Lynch v. Commr, 801 F.2d 1176 (9th Cir. 1986), reversing 83 TC 597 (1984), Seda, 82 TC 484 (1984), and Cerone, 87 TC 1 (1986). At a minimum, read what the case pertains to on the first page of each case, read approximately two paragraphs before the conclusion section (Section IV), and read the conclusion section. Based on the court cases, please write a paragraph (at least four complete sentences) to provide an answer to Nancy's question. Please use correct grammar and spelling
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