Mosby_memocodification

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School

Alabama State University *

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Course

612

Subject

Accounting

Date

May 6, 2024

Type

docx

Pages

2

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ACCT 612 T AX R ESEARCH M EMO T EMPLATE Crystale Mosby Las Vegas, Nevada April 26, 2024 Relevant Facts Chris and Sue own 50 percent shares in BackBone corporation. BackBone provides chiropractic services in four small towns: Troy, Union, Vista, and willow. Chris is the main chiropractor in the Troy office, and Sue heads the Vista office. The two other offices have chiropractor employees running the practices. Specific Issues Charlie is the main chiropractor in the Willow office and he does not see eye-to-eye with Chris and Sue on management styles and how the office is run. Conclusions One option for BackBone corporation is to restructure ownership. BackBone could give Charlie the option to buy shares in willow. This would allow him to have control over that specific location.This would also allow Chris and Sue to still collect profits from the willow location without the day-to-day responsibility. According to the IRS if BackBone sells 30% or more of company shares to Charlie BackBone has the option of sheltering the capital gain tax. Another option for Backbone is a management agreement which can also be conducted like a service agreement. Under section 162 of the Internal Revenue Code BackBone could deduct payments made to Charlie as a business expenses. Depending on the agreement Charlie could have full control of the daily operations of the willow location while allowing BackBone to still receive profits from that location. Support BackBone, Charlie, Chris and Sue should review all options and come to an agreement on terms and conditions based on the agreed agreement to resolve the issues at hand. Actions to Be Taken ________ Discuss with client. Date discussed ________ ________ Prepare a memo or letter to the client ________ Explore other fact situations ________ Other action. Describe:___________________________ _______________________________________________________
ACCT 612 Preparer ________ Reviewer ________ Partner ________
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