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Prepare a letter to Raptor and a memo to the file regarding this matter. Patrick Zimbrick and his son, Dan, own all of the outstanding stock of disallowed deductions for $200000 of the payment to Patrick and $150000 of the
TAX FILE MEMORANDUM. November 1, 2004. FROM: Clara Wong Facts: Dan and Patrick Zimbrick are the sole shareholders of Osprey The IRS recharacterized $200000 of Patrick's salary and $150000 of Dan's salary Pursuant to the 2002 agreement, Dan and Patrick repaid the amount disallowed to Osprey.
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19 Apr 2009 The IRS recharacterized $200000 of Patrick s salary and $150000 of Dan s salary as constructive dividends, disallowing Osprey s compensation
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, , - 2009 - Business & EconomicsIt disallowed deductions for $200000 of the payment to Patrick and $150000 of the payment to Dan. The IRS recharacterized the disallowed payments as books.google.com/books?isbn=0324828632
owed deductions for $200000 of the payment to Patrick and $150000 of the payment . Dan. The IRS recharacterized the disallowed payments as constructive
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, , - 2007 - Business & Economics - 1008 pagesIt disallowed deductions for $200000 of the payment to Patrick and $150000 of the payment to Dan. The IRS recharacterized the disallowed payments as books.google.com/books?isbn=0324380437
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