On January 1, 2008, the Branson Company (EIN 22-2222222) and Porto Engineering, Inc. (EIN 33-3333333), formed Branto LLC (an equally owned joint venture). During its first four years, the LLC worked with the U.S. Department of Homeland Security and the National Transportation Safety Board to design and develop a specific device for airport passenger screening. Porto provides engineering expertise, and Branson provides high-tech manufacturing, selling, and distribution expertise. Early in 2013, the two governmental agencies recommended the product. In 2014, Brantos screening device was being succesfully marketed, sold, delivered, and installed in airports around the United States.

The LLC uses the accrual method of accounting and the calendar year for reporting purposes. Its current address is 3750 Airport Boulevard, Seattle, WA, 98124. The following information was taken from the trial balance supporting the LLCs GAAP-basis (audited) financial statements for the 2014 calendar year:

Revenues:
Sales revenues	$40,000,000
Interest income	50,000
Total revenues	$40,050,000
Amounts related to cost of goods sold:
Beginning inventory	$2,000,000
Materials purchases	8,000,000
Labor	9,000,000
Additional 263A costs	0
Other costs: Various items	2,700,000
Book depreciation	1,275,000
Less: Ending inventory	(3,000,000)
Total amount of work in progress	$19,975,000

Other costs not related to production:

Salaries and wages	$1,000,000
Taxes and licenses (no state income taxes)	300,000
Charitable contributions	100,000
Interest expense	1,200,000
Meals and entertainment (subject to 50% disallowance)	1,200,000
Travel expenses	800,000
Insurance (including key employee life insurance of $100,000)	300,000
Legal and professional fees	900,000
Office expenses	2,000,000
Sales and promotion expenses	1,500,000
Utilities	800,000
Warranty expense (increase to reserves; not fixed and determinable)	300,000
Total other costs	$10,400,000
Net income per books and GAAP-basis audited financial statements	$9,675,000

The beginning and ending GAAP-basis balance sheets for the LLC were as follows at December 31, 2014:

	Beginning	Ending
Cash	$975,000	$825,000
Accounts receivable	620,000	2,600,000
Inventories	2,000,000	3,000,000
U.S. government obligations	1,000,000	1,000,000
Land	600,000	600,000
Buildings and equipment	12,000,000	19,500,000
Accumulated depreciation	(6,375,000)	(7,650,000)
Total assets	$10,820,000	$19,875,000
Accounts payable	$420,000	$800,000
Operating line of credit (guaranteed by members)	1,000,000	5,500,000
Warranty reserves (not guaranteed by members)	200,000	500,000
Mortgage notes on building	5,000,000	6,000,000
Capital, Branson Company	2,100,000	3,537,500
Capital, Porto Engineering, Inc.	2,100,000	3,537,500
Total liabilities and capital	$10,820,000	$19,875,000

The LLC uses the lower of cost or market method for valuing inventory. Branto is subject to 263A; for simplicity, assume that 263A costs are reflected in the same manner for book and tax purposes. Branto did not change its inventory accounting method during the year. There were no write-downs of inventory items, and Branto does not use the LIFO method.

The LLC claimed $2,499,270 of depreciation expense for tax purposes (book depreciation is $1,275,000). All tax depreciation expense should be reported on Form 1125A. The LLC placed $7.5 million of assets in service during the current year; this exceeds the threshold for eligibility for a 179 deduction. Current asset additions are treated as 5-year MACRS assets. The LLC has a positive adjustment of $98,100 for AMT purposes related to tax depreciation (tax depreciation exceeds that allowable for AMT purposes).

All borrowings were used exclusively for business operations; consequently, none of the interest expense is considered investment interest expense. The LLC members were required to guarantee the debt related to the operating line of credit. The accounts payable, accrued warranty claim liabilities, and mortgage were not guaranteed by the members. The mortgage relates to the real property and is considered qualified nonrecourse financing. The partners share equally in all LLC liabilities, because all initial contributions and all ongoing allocations and distributions are pro rata.

The LLCs activities are eligible for the domestic production activities deduction (DPAD). For simplicity, assume that the LLCs qualified production activities income (QPAI) is $9.5 million. Assume the LLCs production-related W2 wages are $10 million. Because of prior state losses and tax concessions, no current or deferred state income taxes are reported for financial purposes.

No guaranteed payments were paid to either of the LLC members. Instead, the members each withdrew $3.4 million of cash during the year. None of the members contributed cash or other property to the LLC during the year.

Both LLC members are U.S. Subchapter C corporations. Both members are classified as domestic corporations and LLC member-managers on Schedule K1.

The IRSs business code for Other specialty trade contractors is 238900. The LLC files its tax return in Ogden, Utah. Branson Company is located at 3750 Airport Boulevard, Seattle, WA 98124 (the same as the LLCs address).

The capital account reconciliation on the partners Schedules K1 is prepared on a GAAP basis, as are the LLCs Schedules L and M2. On the Analysis of Income (Loss), the IRSs instructions indicate that the amounts for any LLC members should be reported on the line for limited partners. The LLC is required to file Schedule M3, Form 8916-A (Supplemental Attachment to Schedule M3), and Schedule C with its Form 1065. The instructions for Schedule M3 state that, if a line description is provided on pages 2 or 3 of the form (or on Form 8916), an income or expense item should be reported on the M3 regardless of whether there is a book-tax difference.

a. Prepare pages 1, 4, and 5 of Form 1065 and Form 1125-A for Branto LLC. Do not prepare Form 4562. Leave any items blank where insufficient information has been provided. Prepare supporting schedules as necessary if adequate information is provided.

b. Prepare Schedule M3 and Form 8916-A (page 1 only). Do not prepare Schedule C or page 2of Form 8916-A. There are four book-tax differences (two temporary differences and two permanent differences).

c. Prepare Schedule K1 for 50% LLC member Branson Company.