Question: In the previous problem, Nancy would like to have Frank stay on as a consultant after all of his shares are redeemed. She would pay
In the previous problem, Nancy would like to have Frank stay on as a consultant after all of his shares are redeemed. She would pay him a modest amount of $500 per month. Nancy wants to know if there is any de minimis rule such that Frank would not be treated as having retained a prohibited interest in the company because he is receiving such a small amount of money. Consult Lynch v. Comm., 801 F.2d 1176 (CA-9 1986), reversing 83 T.C. 597 (1984), Seda, 82 T.C. 484 (1984), and Cerone, 87 T.C. 1 (1986).
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The courts generally have held that there is no de minimis rule in determining if a shareholder has ... View full answer
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