Alpine Corporation is a qualified small business corporation eligible to elect S corporation status. Albert is a shareholder in Alpine. On February 1 of the current year, Albert dies before signing the proper S corporation election form. The stock passes to Alberts estate. Ellen is appointed executor of Alberts estate on May 1 of the current year. On March 10 of the current year, Alpine filed Form 2553, the election form to be an S corporation, properly signed by all March 10 shareholders, and Ellen (the executor) on behalf of Albert. Is this a valid S corporation election?Requirement: Prepare a concise tax memo (no more than 2 pages other than the cover page) including the following elements.Identify the facts and tax issue(s),Locate the Internal Revenue Code Section(s) and Administrative Sources (e.g. revenue rulings) using proper citations. Note that more is not necessary better, select the most relevant and up to date primary sources.Analyze the situation and reach your conclusion.In addition, briefly describe how you found your primary sources, e.g. what keywords you used in searching, what documents/places you have reviewed that lead to the primary sources. Any tips and/or lessons you learned in the research process.
Solution Preview:
Date: November 10, 2016
To: The Client
From: Tax Researcher
Facts: Alpine corporation is small business corporation which is qualified and eligible to elect S corporation status.
In Alpine, Albert is a shareholder
Before signing S corporation election form properly, Albert died on February 1, 2016
The stock was passed to estate of Albert.
On May 1, 2016 Ellen was appointed as executor of estate of Albert
Form 2553, the election form to be an S corporation, properly signed by all shareholders was filed by Alpine on March 10, 2016
