Question: Barry Porter and Winnie Weeks are considering making an S election on March 1, 2024, for their C corporation, Omniocular. However, first they want to
Barry Porter and Winnie Weeks are considering making an S election on March 1, 2024, for their C corporation, Omniocular. However, first they want to consider the implications of the following information:
- Winnie is a U.S. citizen and resident.
- Barry is a citizen of the United Kingdom but a resident of the United States.
- Barry and Winnie each own 50 percent of the voting power in Omniocular. However, Barry's stock provides him with a claim on 60 percent of the Omniocular assets in liquidation.
- Omniocular was formed under Arizona state law, but it plans on eventually conducting some business in Mexico.
- Is Omniocular eligible to elect S corporation status?
For the remainder of the problem, assume Omniocular made a valid S election effective January 1, 2024. Barry and Winnie each own 50 percent of the voting power and have an equal claim on Omniocular's assets in liquidation. In addition, consider the following information:
- Omniocular reports on a calendar tax year.
- Omniocular's earnings and profits as of December 31, 2023, were $55,000.
- Omniocular's 2023 taxable income was $15,000.
- Omniocular's assets at the end of 2023 are as follows:
- On March 31, 2024, Omniocular sold the land for $42,000.
- In 2024, Omniocular sold all the inventory it had on hand at the beginning of the year. This was the only inventory it sold during the year.
- Assume that if Omniocular were a C corporation for 2024, its taxable income would have been $88,500.
How much LIFO recapture tax is (in total) is Omniocular required to pay, and when is the first installment due?
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