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Usually an S Corp would not be desirable in this situation, because down the road if any of the properties need to distributed back out to any of the partners, departing or otherwise the properties have to come out at FMV which could trigger unwanted taxable income. You don't mention, "What is the rationale for these partners to combine together ?" The combining of partners and LLCs into one umbrella organization seems to me to be overly complicated both for both accounting and tax purposes. Inevitably, with this many individuals involved, one or more partners will need to leave whether because of death, financial problems, disagreements etc.. Getting this many individuals headed in the same direction would be like herding cats or watching a train wreck !

I'd write "Refused" in the space for her social security number and paper file. Hopefully here isn't a big refund hanging in the balance. Does the fact that he hasn't filed in 3 years and she refuses to provide the social security number cause you to feel uneasy in any manner? (For me, a couple of alarm bells are sounding.)

Was that disallowed by the IRS? If ultimately there was no tax benefit then I would not report on 4797.

You may still be able to get a transcript of the last return filed, 2015? If she was on it as a joint return, her SSN will be on it. You will have to be registered for both e-services and Secured Object Depository (SOD) where the transcripts will be deliverd. They are no longer faxed, but the good part is that the names, SSN's and addresses are no longer truncated. Of course you will also need form 2848, or 8821.

I'm also thinking out loud, and I have no direct experience with this but do think this would fall under the category of involuntary conversions that includes seizures. When the IRS sells the property to satisfy the debt, if it ends up with excess proceeds, those funds are returned to the taxpayer. Doubtful that would ever happen, but it does seem that this would be reported as a sale. Also to consider when reporting this is that the IRS tallies up all costs associated with the seizure including costs to remove and sell the property, and if the sale does not go through or property is returned to the taxpayer, those costs incurred by the IRS are added to the balance owed to the IRS by the taxpayer. With that in mind, I would think that those costs incurred would be considered additional expenses of "sale" that would reduce any resulting gain from the transactions. Lastly, if any personal property was seized and sold, remember that a loss from the sale of personal property isn't deductible, but any resulting gains would be taxable.

I also would not report this on 4794 If IRS audit said no farm business then they disallowed any deduction on the "farm" equipment. So it would only be reported on Schedule D if a GAIN personal loss not deductible. All deduction for 179 would have been taken care of in the audit.

I don't know if this helps or what other assets were involved, but the IRS gets in line behind those that already have a claim if the property is collateral on an existing loan such as a mortgage on real estate or others with a security interest in the property seized. There are some strict rules where Ch 7 bankruptcy can eliminate some tax debt, but that is a straight outright bankruptcy and not a reorganizing or restructuring.

Oregon is very generous. Oregon residents living in a foreign country may be taxed as foreign nonresidents if they meet the “physical presence” test or the “bona fide residence” test. In which case their foreign income is not taxed by Oregon.

As Catherine and Gail mentioned be sure to get advise on state taxes, some preparers of federal foreign taxes are not familiar with individual state taxes.

The estate attorney should have taken care of funding the bypass trust (B trust). It may not be to late. I was recently involved in an estate where it took three years from date of death to close the estate and fund the bypass trust. The funding date goes back to date of death. If not funded, the purpose of the bypass trust is defeated. The bypass trust gets stepped up basis on date of first spouse to die. If it was never funded you need to talk to estate attorney. There is 2 year window to make the election. The B trust is not a Qualified Revocable Trust so the election does no apply. Hope this helps.

Yes, the year end for estate is May 31, 2019, due date 9/15/19. That depends. If there is both an estate and trust then EIN for both. If there is no estate and you are electing to file the QRT as an estate then use EIN for the trust obtained after DOD.

An honest objective response: This is my second tax season with Drake after 20 years with ATX. To be honest the input is more than a "little" different. Some of the worksheets are very busy with several links to subworksheets. Until you get used to it, sometimes trying to find the right worksheet is frustrating. If you are doing mostly straightforward 1040s, I don't think the transition would be too bad. I do mostly business entity returns and complex 1040s so that transition was more difficult. Drake has Oregon business entity returns available several weeks earlier than ATX which was a big deal for me, plus Drake efiles all of the Oregon entity returns which ATX did not do at the time I left. Honestly it still takes me a bit longer to process returns on Drake than it used to on ATX. However that's more than offset by reduced stress and frustration ! I like Drake and I don't regret changing.

Don't know about now, but back when I used them they would do that if you provided them with available times. I did not use that service, though, 'cuz at the time my available hours were too irregular.