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Tammy Smith is a married farmer who has 80 acres of Almonds. She paid $400,000 for the land many years ago. Seven years ago, she
Tammy Smith is a married farmer who has 80 acres of Almonds. She paid $400,000 for the land many years ago. Seven years ago, she spent $560,000 to develop the orchard and another $150,000 for a drip irrigation system. She has taken $125,000 of depreciation deductions on the trees and $60,000 on the irrigation equipment. She received an offer from Benny Fishiary to purchase the 80 acres, as improved for $3,000,000. Tammy also built her home on the property and lived there for 4 years. In 2014, Tammy moved into town and allowed her father to reside in the home for free. She paid $300,000 to build her home. Tammy will NOT try to accomplish a 1031 exchange and all proceeds of sale will be paid at closing. How can Tammy structure this transaction to minimize her total income tax liability? Explain your answer fully. For purpose of this question, assume the sale will close December 31, 2018; that Tammy is in the 37% income tax bracket, that the rate on capital gains is 20%, and that the rate on unrecaptured 1250 gain is 25%
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