Unicorn Associates is an S corporation for federal tax purposes owned equally by Susan and Jane. Unicorn,
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Unicorn sells hand-crafted furnishings and other home décor items it acquires from unrelated artisans. Unicorn also provides interior decorating consultation services to customers purchasing significant quantities of goods. Neither Susan nor Jane are employed by Unicorn. Each of Susan and Jane have taxable income of $100,000 from sources other than Unicorn. Neither has net capital gain, qualified REIT dividends or qualified PTP income.
In 2018, Unicorn's sales were $14 million and it made an additional $1 million from its decorating consultation services. Its cost of goods sold was $10 million, it paid $500,000 in wages to its employees, and had $2.5 million in other deductible expenses (inclusive of both the furniture sales and consulting activities). Unicorn has no qualified property.
Question: Are Susan and Jane eligible to take a §199A deduction in relation to the net income that flows through to them from Unicorn in 2018? If not, why are they ineligible? If they are eligible, how much would each of Susan and Jane be permitted to deduct?