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Bud Has Devoted His Life to His Business, the BK

question 63

Essay

Bud has devoted his life to his business, the BK Partnership, in which he owns an 85% capital and profits interest. Because he has worked so hard all his life, he never married and has no children. He has decided to give a 25% capital and profits interest to Berry, a close friend, if Berry will work in the business for five years. Berry will receive guaranteed payments for his work. Bud devotes all his time to the partnership, but he takes no salary. What tax issues should Bud and Berry consider with respect to the gift of the partnership interest and Bud's employment arrangement with the partnership?

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Definitions:

Archaea

One of the two prokaryotic domains of life. Archaea superficially resemble bacteria, but they are distinguished by a number of unique biochemical features.

Genetic Polymorphism

The simultaneous occurrence of two or more discrete phenotypes within a population. In the simplest case, each phenotype results from a different allele or combination of alleles of a single gene. In more complex cases, the phenotypes result from complex interactions between many different genes and the environment.

Phenotypes

The set of visible or measurable traits of an organism that arise from the interaction of its genotype with the environment.

Population

A population consisting of members of the same species who live and reproduce within a specific region.

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