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Spin-Off
Taxpayers elect under IRC sec 355 to spin off 100% of
basis and surrender of stock in exchange for stock and
basis in spin-off company, Bishoy, Inc. * * * Business
purpose of change in oil company supplier required this
transaction!
Mina of Forest City filed Forms 1120S for 1996, 1997, and
1998 and reported $30,908 and $48,405 of ordinary income from its
operations in 1996 and 1997, respectively, and a loss of $1,512
in 1998. The Form 1120S filed for Mina of Forest City for 1998
was its final return. On the Schedule M-2, Analysis of
Accumulated Adjustments Account, Other Adjustments Account, and
Shareholders’ Undistributed Taxable Income Previously Taxed,
attached to its Form 1120S filed for 1998, Mina of Forest City’s
accumulated adjustments account was reported to have a balance of
$64,681 as of the end of that year. John L. Bradshaw, P.A.,
C.P.A. (Bradshaw), prepared these Forms 1120S for Mina of Forest
City.
In a letter dated November 10, 1999, and addressed to
Bradshaw, the Internal Revenue Service (IRS) granted Mina of
Forest City S corporation status with an effective date of
January 1, 1995.
G. Micca, Inc.
In April 1995, Micca, Inc. (Micca), was organized as a
Florida corporation. Messrs. Gowni and Mansour owned and
operated Micca. Micca operated as a C corporation during the
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Last modified: May 25, 2011