Sarah is the sole owner of Bluegrass Corporation. The basis and value of her stock investment in

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Sarah is the sole owner of Bluegrass Corporation. The basis and value of her stock investment in Bluegrass are approximately $100,000. In addition, she manages Bluegrass's operations on a full-time basis and pays herself an annual salary of $40,000. Because of a recent downturn in business, she needs to put an additional $80,000 into her corporation to help meet short-term cash-flow needs (e.g., inventory costs, salaries, and administrative expenses). Sarah believes that the $80,000 transfer can be structured in one of three ways: as a capital contribution, as a loan made to protect her stock investment, or as a loan intended to protect her job. From a tax perspective, which alternative would be preferable in the event that Blue grass's economic slide worsens and bankruptcy results? Explain your answer.

Partial list of research aids:

Kenneth W. Graves, 87 TCM 1409, T.C.Memo. 2004-140.

Corporation
A Corporation is a legal form of business that is separate from its owner. In other words, a corporation is a business or organization formed by a group of people, and its right and liabilities separate from those of the individuals involved. It may...
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South Western Federal Taxation 2018 Corporations Partnerships Estates And Trusts

ISBN: 1389

41st Edition

Authors: William H. Hoffman, William A. Raabe, James C. Young, Annette Nellen, David M. Maloney

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