Joe called me, wanting a second tax opinion for a business-transfer plan and an estate plan he put in place almost two years ago. He owns 98 percent of two corporations: a profitable S corporation (Success Co.), and a C corporation (a tax-paying corporation, called R/E Co.), which owns real estate leased to Success Co. The real estate has an income tax basis of 1 million dollars but a current fair market value of about 6 million dollars. His son Sam owns the remaining two percent of the stock of both corporations. Each of the corporations is the owner and beneficiary of a separate 1 million dollars insurance policy on Joe's life.
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