Tax Drill $-$ Section $721$ Exceptions

Wozniacki and Wilcox form Jewel LLC$,$ with each receiving a one$-$half interest in the capital and profits of the LLC$.$ Wozniacki receives his one$-$half interest as compensation for tax planning services he rendered prior to the formation of the LLC$.$ Wilcox contributes $$50,000$ cash. The value of a one$-$half capital interest in the LLC $($for each of the parties$)$ is $$50,000.$