Primco Management Company, Alfred Dreyfus Goldman Revocable Living Trust, Alfred D. Goldman, Fiduciary, Tax Matters Person - Page 5

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          97-354, 96 Stat. 1691-1692.5  Subchapter D provides that the                
          items of income, loss, deduction, and credit of S corporations              
          generally will be determined in a unified manner at the corporate           
          level as opposed to the individual shareholder level.                       
               Section 6241 provides express authority for the Secretary to           
          prescribe regulations that create exceptions to the unified S               
          corporation audit and litigation procedures.  On January 27,                
          1987, the Secretary promulgated section 301.6241-1T(c)(2),                  
          Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003 (Jan. 30,               
          1987), providing an exception to the unified S corporation audit            
          and litigation procedures for small S corporations.  Section                
          301.6241-1T(c)(2), Temporary Proced. & Admin. Regs., is effective           
          for any taxable year of an S corporation the due date of the                
          return for which is on or after January 30, 1987.  Sec. 301.6241-           
          1T(c)(2)(i), Temporary Proced. & Admin. Regs., 52 Fed. Reg. 3003            
          (Jan. 30, 1987).  The section provides in pertinent part as                 
          follows:                                                                    
                    (2) Exception for small S corporations--                          
                         *    *    *    *    *    *    *                              
                         (ii) Five or fewer shareholders.  For                        
               purposes of this paragraph (c), an S corporation shall                 
               not include a small S corporation.  A small S                          
               corporation is defined as an S corporation with 5 or                   

               5 Subchapter D, consisting of secs. 6241 through 6245, was             
          repealed applicable to tax years beginning after Dec. 31, 1996.             
          Small Business Job Protection Act of 1996, Pub. L. 104-188, sec.            
          1307(c)(1), 110 Stat. 1755, 1781.                                           




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