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someone need to answer these tax problems. The answer must be supported by Internal revenue code and Regulation ruling. If the answer not following the

someone need to answer these tax problems. The answer must be supported by Internal revenue code and Regulation ruling. If the answer not following the my requirement, I will not pay. I can very easy to just answer these question.image text in transcribed

Jeffery Dion and Richard Rick formed Friendly Equipment Corporation on January 1, 2010. The corporation was organized as a closely-held \"C\" corporation that provides equipment maintenance and repairs to oil field service contractors. Jeffery Dion and Richard Rick were college roommates and are not related. Friendly uses a calendar year for reporting and is on the accrual basis of accounting. Jeffrey's and Richard's initial contribution to form the corporation was $500,000 each. The $500,000 contribution consisted of $200,000 in cash to the corporation in exchange for common stock of the corporation with an equivalent fair market value and $300,000 in \"Advances (loans) to the Corporation. Each shareholder's interest represents 50% ownership of the corporation. Friendly used $400,000 of the proceeds from the Advances to purchase machinery and equipment for the corporation and $200,000 was set aside for the operating needs of the business. Both Dion and Rick are employed full-time by the corporation and are paid competitively for their services. Jeffrey is President of Friendly and Richard is Secretary/Treasurer. The \"Advances to the Corporation\" were properly recorded in the corporate minutes with the following terms and conditions: 1. The Advances to the Corporation were to be repaid on a semi-annual payment basis consisting of principal and interest at the prevailing market rate of interest of 6%. 2. The above semi-annual payment could be deferred by the corporation if it did not have sufficient cash flow for operations or if the payment would jeopardize the liquidity of the business. 3. The payoff of the debt did not have a certain maturity date because of the above provision. 4. At the end of 10 years, Dion and Rick have the option to receive additional Friendly Corporation common stock at a fair market value equivalent to the balance of their respective debt obligation due from the corporation. 5. At the end of 10 years, Dion and Rick also have the option to re-new the terms and conditions of the debt repayment, including adjusting the interest rate to the prevailing market rate of interest at the end of the 10-year period. The corporation made semi-annual payments of $15,000 plus 6% interest in 2010 through December 31, 2013. The corporation deducted the interest payments under Section 163 of the Code as an ordinary and necessary business expense and Dion and Rick included the interest payments in their respective income. No payment on the debt was made in 2014 because Dion and Rick were concerned about the liquidity of the corporation. However in 2014, a journal entry was made on the corporate books debiting interest expense with an offsetting credit to Advances to the Corporation. Required: Dion and Rick engage you to assist them with the preparation of their individual and the corporate Federal Income Tax Returns for 2014. Additionally, the taxpayers request your review and analysis of the initial incorporation of Friendly Equipment Corporation. Specifically, Dion and Rick would like to know: 1. Whether or not there are any possible adverse tax consequences to the initial incorporation of Friendly Equipment Corporation? 2. Whether or not there are any tax consequences of the non-payment of principal and interest by the corporation in 2014 (specifically if the corporation is entitled to an interest deduction and whether or not individually they must include interest income)? Each answers must be supported by Internal Revenue Code or Regulation ruling

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