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XYZ, LLC Has Several Individual and Corporate Members

question 103

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XYZ, LLC has several individual and corporate members. Abe and Joe, individuals with 4/30 year-ends, each have a 23% profits and capital interest. RST, Inc., a corporation with a 6/30 year end, owns a 4% profits and capital interest while DEF, Inc., a corporation with an 8/30 year end, owns a 4.9% profits and capital interest. Finally, thirty other calendar year-end individual partners (each with less than a 2% profits and capital interest) own the remaining 45% of the profits and capital interests in XYZ. What tax year-end should XYZ use and which test or rule requires this year-end?

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Definitions:

Good Faith

The sincere intention to be fair, open, and honest, regardless of the outcome of the interaction.

Authenticity

The quality of being genuine or not counterfeit or copied, often verified through documentation or expert examination in the context of art, documents, or items of historical significance.

Negotiable

Relates to legal instruments, such as checks or bills of lading, that can be transferred from one party to another, changing ownership by endorsement.

Particular Fund

A specific investment fund targeted toward certain assets or investment strategies.

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