I need to identify three tax issues and have an analysis for each one. You do not have to go into detail but tell me three issues, an analysis for each issue, and a primary authority for each issue. Easy money but I need accurate work. An example of one issue is how much loss/gain is Juan going to recognize in Year 1, Year 2, and Year 3? Explain how you got the number and primary authority to back it up. Any other issues you can think of and an analysis would be huge.

Juan Estefan formed Beta Corporation on January 4th of Year 1, and the corporation immediately made an S election effective for that year. Beta Corporation is involved in the Beta testing of software and games for other software companies. In forming the corporation, Juan contributed $50,000 cash in exchange for 100% of the Beta Stock. Shortly thereafter, the corporation obtained a $25,000 bank loan to assist with operations. Beta's first two years did not go as well as expected, Beta incurred ordinary losses of $60,000 and $20,000, in years 1 and 2 respectively. In addition in Year 2 Juan and his wife Marta divorced. As part of the divorce settlement, on June 30th of Year 2, Juan gave Marta 50% of the Beta Stock. It is now the beginning of year 3, Beta's performance finally improved, with the corporation estimated to earn $40,000 of ordinary income. Juan asks your firm to help in determining the tax consequences of these events, particularly the usage of the S corporation losses, you will be meeting with him to discuss his options in a few weeks along with your manager. Required: Write a tax research memo to the file that your manager will review in order to help determine how the firm should advise Juan. At a minimum you should consider IRC 1366. The research memo should be 4-7 pages long. Follow the format outlined in the M. Tx. Writing Website as indicated in the syllabus. Thus, the memo should include a restatement of the facts, at least three key tax issues, conclusions and analysis for each issue. Be sure to cite only primary authority. Internal Revenue Publications and the textbook are NOT primary authority. There is a list of items in this folder that are primary authority and examples of how they are cited. Be sure that your similarity rating should be no higher than 20%. Do NOT cut and paste, paraphrase