Our former client, Mr. Calvin Corn, was the sole shareholder of Rutabaga Farms, Inc., a Michigan corporation. The corporation was in the business of...

Our former client, Mr. Calvin Corn, was the sole shareholder of Rutabaga Farms, Inc., a Michigan corporation. The corporation was in the business of growing a variety of agricultural products. The corporation also maintained a small herd of cattle for milk production.

In 2016, the corporation deducted about $500,000, representing all of the costs and expenses incurred in connection with the harvesting and cultivation of its crops. It also purchased and deducted about $100,000 of cattle feed expenses.

Unfortunately, late in 2016, Mr. Corn died and in January of 2017 the executors of his estate elected to liquidate the corporation. The principal assets of the corporation, which were distributed to Mr. Corn's estate in 2017, consisted of the harvested and unharvested crops grown during the year, the cattle and about $40,000 worth of the cattle feed that had been purchased in 2016. Because the estate received a basis in the corporation's stock equal to the fair market value of the stock as of the date of the decedent's death, the estates gain on the section 331 liquidation was zero and we have so advised the estate. However, I am uncertain as to whether any gain has to be recognized at the corporate level and, if so what the character of any such gain would be. We will need to know this information in order to prepare the 2017 tax return.

A memorandum to me addressing these tax issues.