Oh, this thing is full of fun. There is also the issue of donating a partial interest, and last I heard the genius tax attorney was going to amend the operating agreement to allow a "non voting" class. I'm just a hack, but I think to deduct a partial interest, it has to be an undivided share, meaning that the donee has the same rights as the donor. I sent an email to the geniuses and have asked for an opinion. The client wants to do this RIGHT NOW because he thinks a buyer will be identified on Thursday, and then it's too late.
I do the bookkeeping for this partnership for a nice fat monthly fee. That will go away when they sell. So, I'm not even real motivated to keep the client for just his wife's 1120S and their 1040 if it means a lot of knuckle biting next tax season over this. I'm too old and too ornery and too tired to enjoy slogging into weird and murky water like this.
Thank you so much for taking a look at this.