Research Problem 2

Barney, an individual, and Aldrin, Inc., a domestic C corporation, have decided to form BA, LLC. The new LLC will produce a product that Barney recently developed and patented. Barney and Aldrin, Inc., will each own a 50% capital and profits interest in the LLC. Barney is a calendar year taxpayer, while Aldrin, Inc., uses a July 1 -June 30 fiscal year. The LLC does not have a -natural business year- and elects to be taxed as a partnership.
a. Determine the taxable year of the LLC under the Code and Regulations.
b. Two years after formation of the LLC, Barney sells half of his interest (25%) to Aldrin, Inc. Can the LLC retain the taxable year determined in part (a)? Why or why not?
Please cites also and need 3 pages included excel sheet.

Primary sources to search:
Section 706 (b) (1)
Section 706 (6) (4) (A)
Regulation: 1.706-1 (b) (3) (i)
1.706-1 (b) (9)

Section 444
Revenue Procedure 2006-46

The topic for search:
(a) Can be fiscal or calendar year. (Doing calculations for request following all the above rules make excel table or word table.
(b) There will be a sale?
Please use all the rules above.

To solve the A part please follow below example: This example is very similar to part A. Its helps you to find the least aggregate deferral method. You can use MS Word also to solve the problem.
Cerulean, Inc., Coral, Inc., and Crimson, Inc. form the Three Cs Partnership on January 1 of the current year. Cerulean is a 50%partner, and Crimson and Coral are 25%partners. For reporting purposes, Crimson uses a fiscal year with an October 31 year-end, Coral uses the calendar year, and Cerulean uses a fiscal year with a February 28/29 year-end. What is the required tax year for Three Cs under the least aggregate deferral method?
SOLUTION:

Cerulean 28/29
Cerulean   50% owner = 28/29   0*50%      = 0
Crimson    25% owner = 10/31   8*25%       = 2
Coral       25% owner = 12/31    10*25%    = 2.5
4.5 Cerulean

Crimson 10/31
Cerulean 4*50%    = 2.0
Crimson 0 * 25%    = 0
Coral 2 * 25%        = .5
2.5 Crimson

12/31 Carol
Cerulean 2 * 50%     = 1
Crimson 10 * 25%   = 2.5
Carol    0 * 25%        = 0
3.5 for Carol

February 28 year end = 4.5
October 31 year end = 2.5
December 31 year end = 3.5