Question - Jean and Paul are equal partners in the J&P Partnership. The partnership will form J&P Corporation by exchanging the assets and liabilities of the J&P Partnership for all of the corporation's stock on August 1 of the current year. The partnership will then liquidate by distributing the J&P Corporation stock equally to Jean and Paul. Both shareholders use the calendar year and desire that the corporation make an S election.
What tax issues should Jean and Paul consider with respect to this contemplated transaction?