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1F Structuring the will of a shareholder to allow
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adjusted AE&P allocation alternative minimum tax amount annual apply assets avoid basis in stock book income built-in gains tax capital gains cash flow Chapter computed corporate income corporate level corporate tax corporation election corporation status debt basis December 31 deduction discussed distributions dividend earnings and profits earnings tax effective electing S status eligible employer identification Esscorp excess net passive FACT PATTERN filed Form hobby loss income tax ISSUE limited LlFO loan lRC Sec lRC Section materially participates method nontaxable ordinary income partnership passive activity passive income poration post-termination transition period prorata QSST qualified recapture reduced regular corporate reporting Revenue revocation RTB Corp rules salary section 444 share shareholder shareholder's short-period return stock basis Study SUBTOPIC tax cost tax on built-in tax planning tax practitioner tax rate tax return taxable income taxation Taxco termination tion trust