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Scenario: Unicorn Associates is an S corporation for federal tax purposes owned equally by Susan and Jane. Unicorn, Susan, and Jane are all calendar year

Scenario: Unicorn Associates is an S corporation for federal tax purposes owned equally by Susan and Jane. Unicorn, Susan, and Jane are all calendar year cash method taxpayers. Susan and Jane each file Single returns.

In 2019, Unicorns decorating consultation services take off and the company decides to discontinue direct sales of furnishings and dcor to the public. Unicorn continues to sell some items to decorating clients as part of their services. Neither Susan nor Jane are employed by Unicorn. Each of Susan and Jane have taxable income of $100,000 from sources other than Unicorn. Neither has net capital gain, qualified REIT dividends or qualified PTP income.

Unicorns 2019 receipts on its consulting services were $16 million, and it had sales of furnishings and other items of $4 million. It had cost of goods sold of $3 million, it paid $2 million in wages to its employees, and had $4 million in other deductible expenses (inclusive of both the furniture sales and consulting activities). Unicorn has no qualified property.

Question: Are Susan and Jane eligible to take a 199A deduction in relation to the net income that flows through to them from Unicorn in 2019? If not, why are they ineligible? If they are eligible, how much would each of Susan and Jane be permitted to deduct?

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