Problem: Analyze how corporations treat non-liquidating distributions and determine the most likely mistake(s) the client could make that would result in an IRS audit. Advise the client on how to avoid the mistake(s) and how you would respond to the IRS inquiry if an audit request is received.
Take a position as to whether the current tax rules related to the payment of dividends are fair. Support your position with examples. Propose an alternative to the current tax rules that would be fairer.