Answered step by step
Verified Expert Solution
Link Copied!

Question

1 Approved Answer

Suppose you are a CPA hired to represent a client that is currently under examination by IRS. The client is the president and 95% shareholder

Suppose you are a CPA hired to represent a client that is currently under examination by IRS. The client is the president and 95% shareholder of a building supply sales and warehousing business. He also owns 50% of thr stock of a construction company. The client's son owns the remaining 50% of the stock of the construcyion company. The client has received a Notice of Proposed Adjustments (NPA) on three (3) significant issues identified in the NPA are unreasonable compensation, stock redemptions, and a rental loss, Unreasonable compensation: The taxpayer receive a salary of $10 million composed of a $5 million. The total gross receipts of the building supply business are $300 million. The NPA by the IRS disallows the salary based on 5% of gross receipts as a constructive dividend. Stock redemptions: During the audit period, the construction company redeemed 50% of the outstanding stock owned by the client and 50% of the stock owned by the client's son, leaving each with the same ownership percentage of 50%. The IRS treated the redemption as a distribution under Section 301 of the IRC. Rental loss: The rental loss results from a building leased to the construction company owned by the client. Use the internet to research the rules and income tax laws regarding unreasonable compensation, stock redemptions treated as dividends and related party losses. Write a three to four (3-4) page paper in which you (1) Based on your research and the facts stated in the scenario, prepare a recommendation for the client in which you advise either acceptance of the proposed adjustments or further appeal of the issue based on the potential for prevailing on appeal, (2) Create a tax plan for the future redemption of the client's stock owned in the construction company that will not be taxed according to Section 301 of the IRC. (3) Propose a strategy for the client to receive similar amounts in compensation in the future and avoid the taxation as a constructive dividend.

Step by Step Solution

There are 3 Steps involved in it

Step: 1

blur-text-image

Get Instant Access to Expert-Tailored Solutions

See step-by-step solutions with expert insights and AI powered tools for academic success

Step: 2

blur-text-image_2

Step: 3

blur-text-image_3

Ace Your Homework with AI

Get the answers you need in no time with our AI-driven, step-by-step assistance

Get Started

Recommended Textbook for

Unofficial Guide To Medical Research Audit And Teaching

Authors: Ceen-Ming Tang BA BM BCh MRCGP, Colin Fischbacher, Zeshan Qureshi BM BSc MSc MRCPCH FAcadMEd MRCPS

1st Edition

0957149980, 978-0957149984

More Books

Students also viewed these Accounting questions

Question

Connect with your audience

Answered: 1 week ago