EFTA01108510.pdf

KCAC Actions Required Explanation a) File 2012 KCAC Partnership a) records $405k of capital Return (form 1065) reflecting improvements made by DKI in $405k capital contribution to the property Michelle Saipher capital account (cumulative) which mathematically would change % ownership to 52.7% Michelle and 47.3% JE b) In 2013, JE gifts $1,823k to b) provides DKI with funds to repay Darren by wire or check JE for the, $698k borrowed by Michelle for the property down payment, $525k for Michelle to buy out JE's 47.3% interest in KCAC, and $600k for DKI to repay his loan to NVSG c) In 2013, Darren gifts to Michelle c) to provide Michelle with funds to $1,223k repay the $698k & $525K per b) above d) An agreement is drafted by d) enables Michelle & DKI to get full which Michelle buys out JE's ownership of the property. Due interest for 50% of capital to JE wanting with withdraw but account (capital account and owning only a non-control FMV being similar), or $525k minority interest in an illiquid investment with an indefinite life, Michelle buys out JE's interest for 50% of capital account (capital account and FMV being similar), or $525k. JE sustains a $525k capital loss on the sale e) Michelle repays $698k borrowed e) loan to JE fully repaid to originally fund KCAC purchase EFTA01108510