Mandy has established a very successful adventure travel agency, estimated to be worth $2,000,000. Mandy has used a corporate recapitalization to turn the future value of her business over to her children, both of whom are involved in running the business. She has retained voting preferred shares, and the children were given non-voting common stock. If the corporation is liquidated within five years of the recapitalization, Mandy will receive 110% of the preferreds stated par value before the common will receive anything.

a. For transfer tax purposes, what is the maximum amount that Mandy can value stock she retains?

b. What happens if the corporation fails to pay dividends on the preferred stock?

c. For transfer tax purposes, does the liquidation bonus in the event of liquidation within five years increase the value of the preferred shares?