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X has one shareholder, A, whose stock basis is $100. X operates a business in a building whose value is $1,000, with an adjusted basis
X has one shareholder, A, whose stock basis is $100. X operates a business in a building whose value is $1,000, with an adjusted basis of $300. X has $1,000 in the bank. In the current year, X sells its operating business assets for $1,000 cash, which increase X's total E&P to $1,500. Also in the current year, in exchange for other assets X receives an installment note reportable under section 453, enters into a lease for the building with the buyers of its business, and retains part of its inventory for gradual sale in the future. A, who is age 70, comes to you after all these steps have been taken and inquires whether X should be liquidated or should elect S corporation status to avoid paying double tax on the installment gain, the rent, the future inventory sales, and a possible sale of the building in a few years. What do you advise?
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