EFTA01108509.pdf

KCAC Actions Required a) records $405k of capital a) File 2012 KCAC Partnership improvements made by DKI in Return (form 1065) the property reflecting S405k capital contribution to Michelle Saipher capital account (cumulative) which mathematically would change % ownership to 52.7% Michelle and 47.3% JE b) provides DKI with funds to repay JE for the, $698k b) In 2013, JE gifts 51,823k borrowed by Michelle for to Darren by wire or check the property down payment, $525k for Michelle to buy out JE's 47.3% interest in KCAC, and $600k for DKI to repay his loan to NYSG c) to provide Michelle with c) In 2013, Darren gifts to funds to repay the $698k & Michelle 51,223k $525K per b) above d) enables Michelle & DKI to d) An agreement is drafted by get full ownership of the which Michelle buys out property. Due to JE wanting JE's interest for 50% of with withdraw but owning capital account (capital only a non-control minority account and FMV being interest in an illiquid similar), or S525k investment with an indefinite life, Michelle buys out JE's interest for 50% of capital account (capital account and FMV being similar), or $525k. JE sustains a $525k capital loss on the sale e) Michelle repays S698k borrowed to originally fund e) loan to JE fully repaid KCAC purchase Explanation EFTA01108509