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Corporate liquidating dividend
In a professional practice, tangible property such as office equipment, furniture and fixtures makes up a small portion of a firm’s total value.By far the largest element of value in a profitable professional practice is the intangible .WHETHER PLANNING FOR A LIQUIDATION of their own professional practices or advising clients about the liquidation of a commercial organization, CPAs will find that the problems and the solutions associated with each are likely to be the same.
When such a business distributes its property, it generally is deemed to have sold the property at fair market value, which requires it to recognize a gain (IRC section 336(a)).
There’s no doubt that a firm can distribute tangible property to its shareholders as a dividend, whether it liquidates or not.
But a question arises when it distributes to its shareholders all its assets—both tangible and intangible—and ceases doing business: Is there a taxable distribution of its intangible goodwill? According to the Tax Court, on the other hand, the answer is that it depends.
The IRS determined their firm had realized a 8,000 gain on liquidation of its goodwill and Norwalk and De Marta, as shareholder partners, realized capital gains from the distribution of the goodwill.
The IRS argued that when the corporation was liquidated, it distributed to its shareholders “customer-based intangibles” in addition to tangible assets.