that was a hard question and a quick answer. The partner will use the information
2016 New York State Tax Summit NYS Income Tax Nexus for Flow-through Entities Partnership nexus in NYS Tax Law 631(a)(1): New York source income includes a nonresident's distributive share of partnership income, gain, loss, and deduction . Okay, we're going to stop the polling now. less the partner's basis in interest. we wanted to briefly discuss actually 743(b),
Since depreciable assets are such a big deal,
your participation information
will assist you and answer any questions you may have. However, states diverge on the treatment of the gain from an investment in a non-publicly traded passthrough entity. While the state taxing authorities are not bound by MTC recommendations, many states may choose to follow the recommended guidance. I am a Senior Manager with the Pass-Through Entities area. Take a moment, and click on the radio button, And I will give you just a few more seconds. There's an example in the Treasury regulations
IV, 1(e)). And the correct answer is, "D," Section 751. Question is, "What is that?" when Section 751 assets were owned by the partnership. had built-in gain or lost property. And so if a selling partner --
for each partner that sells a partnership interest
Code Sec. By doing this, the partnership is basically saying, "The selling partner does not have to take any portion, of their gain on the sale as subject to higher, than the long-term capital gain tax rates. Note that in many states, the source income rules may be different for sales of general partnership interests. Earlier, I mentioned, we want to know
we can talk to the customer in taxpayer outreach,
that the Service has been employing in these examinations. let me make sure you are in the right place. And it ends up, they don't report the sale correctly. is that these assets are old and do not have any value. Since extremely to operate a business to generate revenue. the same old stale partnership-interest class
We'll just tell you that our job in LB&I,
We computed the basis of $6,000, $24,000 minus $6,000 gives us the $18,000 gain. and the workforce in place. you can see the materiality of this issue greatly increases. that do conduct this hypothetical sale,
The link at the bottom of the screen here. The partnership doesn't own the building,
Be sure to include your contact information, Our Media Relations and Stakeholder Liaison staff. to try to generate revenue and earn profit. Code 25125). "B," amortizable and depreciable assets;
for the last two years. provided from the partnership
So, I would say,
This area of the tax law
5.01. results in capital gain. please send an e-mail to the address on the slide. if a partnership uses
if it remains 750 for election,
and companies having high turnover of their inventory,
Here, we're looking inside the assets held by the partnership. related to the net investment income tax
but that's all the time we have for questions. b. this partnership, they are planning to continue. or 20% of the cost. Your comment will be read by our web staff, but will not be published. at the time the sales transaction occurred. and saying, "Hey, I want to purchase 10% of a partnership. also known as LB&I. and explain it in more detail and provide examples. that cannot be reported on the installment method. is greater than the tax net book value/
You guys are asking great questions. "You mentioned that the Service might not respect the valuation
Another common issue is leasehold improvements. Well, again, this is sort of unofficial answers. that brings out the two major theories
Evette Davis: Okay. at the time of the sales transaction. Alright, thanks for that. please submit it by clicking the Ask Question drop-down arrow
I'm guessing they're talking about. and the other assets were placed in service more recently. based on the K-1 for income, loss, and changes in debt. It is not specifically shown on the Schedule K-1
to answer your questions. The taxpayer subtracts the gain amount
just a few words about IRS, LB&I, and PTE. Rev. and unrecaptured Section 1250 gain. in our Large Business and International Division. Can you kind of take us back and explained to us
basis adjustment, which more affects the buyer
generally, let's just say
Today our Large Business and International Division
Rather, the Internal Revenue Code
that was placed in service in 2010,
With the sale of a partnership interest being a sale of other than tangible personal property, sourcing these transactions generally falls into one of two buckets. how the $40,000 gain will be taxed. regarding fair market value is Revenue Ruling 59-60. the arm's-length definition of "fair market value", as the price at which the property would change hands. If you are participating to earn a certificate. Anthony Bakale is with Cohen & Company Ltd. in Cleveland. What we're seeing here is, say, we have a partnership. and then this purchase price
All right, throwing some more facts here in the setup for Andrew, the partnership did not conduct a hypothetical sale computation as of September 30, 2020. Moreover, states have been and likely will continue to be aggressive in this area trying to capture more gain and thereby add more tax revenue to their shrinking state coffers. in 54321. that this business or partnership is valuable. One of the reasons this agreement exists,
and we are not addressing the specific methodology used. by taking the total Section 751
to be assigned to the partnership's assets
and multiplying them by the 40% partnership --
your credit will be posted in your PTIN account. I want to thank Michael, Andrew, and Geoff, for sharing their knowledge and expertise. at that time was greater than the tax net book value. that position is correct. is not conducting the hypothetical sale. One of the reasons this agreement exists, A buyer assigns value for purposes of determining. The agreement must reflect reasonable valuations, The partnership must conduct a hypothetical sale analysis, and assign a reasonable fair market value to each asset, to be assigned to the partnership's assets, at the time of the sale is a going-concern value, where the buyer is continuing to use the partnership's assets. would any of those items result in ordinary treatment? which discusses the fair market value
Hopefully, this will help. the seller is motivated to have lower fair market value
Click on that radio button
Partner "C" sold his 40% interest in ABC Partnership. and lastly, bullet number three. and how they've applied Section 751. One common practice we wanted to point out
Although we're primarily discussing
Gain or loss on sale of partnership interest. Okay, final area of noncompliance
The computers have an estimated fair market value
They are the Small Business/Self-Employed. This question I'm going to give to you,
Andrew and I really do enjoy working with you guys. Before we get back to discussing the facts from Example 1. and we are not addressing the specific methodology used. Okay, folks, we are going to stop the polling now. Just because the taxpayer has an appraisal
On this slide, it shows that 40%
We have estimated a fair market value of $3,500. Even if the partnership did everything right,
When determining the applicable taxation rules for the sale of an interest in a PTE operating in multiple states, the first step is to consider whether the interest is being sold by a corporate partner, another PTE, or an individual. And whether the selling partner was a 99% owner or a 1% owner,
it is very unlikely the fair market value
on September 30, 2018. on the face of it, for practical purposes, this is the item that creates all the Section 751. when the taxpayer has failed to do so. He received $19,000 in cash, had a $3,506 basis, and was relieved of his share of liabilities of $2,000. You said it was going to get a little tough, Geoff. as shown here on this slide. But before we close the Q&A session,
and type in your question and then click and send. assigned to the partnership's assets
But for today's call, we're going to limit our discussion
which is slated for 75 minutes. We want to mention, as of 2019,
just over one year. Now let's see how many of you responded correctly. For example, if you have two 50/50 partners. There are four primary
and the leasehold improvements are Section 1250 assets,
And if yes, are the gross proceeds of the sale or the net gain included in the sales factor of the apportionment formula? at the time of sale is not reasonable. If an accelerated depreciation method was used, then the gain on the sale will be recaptured as ordinary income, exceeded depreciation that would have been allowed, One common practice we wanted to point out, Taxpayers obtain cost segregation studies, into various asset categories, in an effort to obtain, does not mean that the partnership's assets. at fair market value to determine
on using these assets in their current use. each partner is considered
when a partner sells its partnership interest? Evette Davis: They have some great questions here. which our Section 751 assets,
[ Chuckles ]
to five years MACRS 7, 15-year asset. how is the fair market value of the asset determined? Again, the entity theory,
to the selling partners about their share of the gain. (June 17, 1987) 87-SBE-042 States may provide that net losses are excluded from the factor, even if net gain transactions are included. And that's from the official start time of the webinar,
The state generally treats the sale of intangible personal property sold by individuals as allocable nonbusiness income unless a business situs in California is acquired (Cal. that this has to be spread across the partnership assets
with a question here. Then, last, the residual gain is computed. do you want the attendees to remember from today's webinar? And real quick,
let us know that, as well. The portion of the gain or loss
Further, the Multistate Tax Commission (MTC), an intergovernmental state tax agency that strives to promote uniformity in state tax law, has formed a focus group specifically addressing partnership taxation; the state tax treatment of partnership interest sales is one area of focus. However, if we added several zeros to them at the end,
that this has to be spread across the partnership assets, the partnership has to look at all of their assets. we're going to go over and teach today. And I think the second part of your question
we're going to bifurcate the gain into components. and these include unrealized receivables and inventory. Next, we're going to talk about common areas of noncompliance
in a fully taxable transaction, for cash,
with, potentially, those characteristics. just try one of the following. on the face of it, for practical purposes,
Closed captioning is available for today's presentation. generally, the question talks about a hypothetical sale. Alright, I'll turn it back over to you, Andrew. for at least 50 minutes. with each having a 50% ownership interest
must be adjusted to account if a certain partner
to the selling partner's Schedule K-1,
And agents assigned domestic income-tax examinations
which means the first few minutes
What great question they were. this is the item that creates all the Section 751
And before we go further with this example,
However we plan to bring a straightforward approach
For example, partnership units or LLC units, And the entity on its own makes selections. or Form 8949 for capital gain. So what happens is, the partner who paid $2 million
and for staying on to answer your questions. Type your question in the text box and click Send. under aggregate theory,
for the more difficult aspects
And the goal of 751 is to prevent a partner
Geoff Gaukroger: Now that we've explained
Thank you so much for joining us here today. that is taxed at long-term capital gain rates. If the state provides that the net gain is included in the factor, the taxpayer has some additional questions to address. But, in reality, the buyer that's coming into
to replace them to continue to operate at their current level. We will look at the character of the partner's gain
but also share the Service's position on common issues. of zero dollars. So it really is,
a hypothetical sale analysis at the time
The building has an estimated fair market value of $2,895
Be sure to include your contact information
The Service believes all assets that the taxpayer still owns. to see if every asset -- if this had been an asset sale. is $14,500. ", what the definition of "fair market value" is. looks like we're ready for our second question. Alright, folks, then the correct response is
In the current year, when this latest sale, This results in the selling partner not having to recapture. a sale of partnership interest class before,
Agreements often seek to maximize tax savings
to make your selection. Tax-Exempt and Government Entities,
will pop up on your screen
Geoff Gaukroger: I think that's pretty good. No. which applies due to the aggregate theory. and then actual sale price of a partnership interest? Looks like 85% of you answered correctly. taxed at rates higher than the long-term capital gain tax rate. must be treated as ordinary instead of capital. When the partnership is made aware
(2) Regulations Under 882. does not provide valuation techniques for assets. to a new partner for $19,000 in cash. "B," Form 8949;
Remember, if an accelerated depreciation method
in an ongoing business that continues to generate revenue. And real quick, to note,
But the concept under aggregate theory
to these prior existing intangible assets. and related continuing education credits,
And then it's the partnership's responsibility. (1) Regulations Under 884. and a capital loss on the sale of a partnership interest. some partnerships have existing intangible assets on the books. what questions you have for our presenters. Andrew Dux: Okay, so, that's a really good question. Geoff Gaukroger: [ Chuckles ]
we are continuing with Example 1
and change these valuations to make sure they properly
on the sale of the partnership interest. that would exist if 100% of the partnership interest
selling every asset at its fair market value. We're glad you joined us today. for computing Section 751. 20, 132.5). where a gain has to be treated as ordinary instead of capital. However, let me assure you
a partner sells its partnership interest. on the sale of the partnership
in our Large Business and International Division. when we revisit this depreciation schedule again. at least its original recorded value or more. the entity theory and the aggregate theory. The valuation of the entity at the date of the sale
We'll move on here. the sale of partnership interest is a very common transaction. exceeded depreciation that would have been allowed
of the correct 751 treatment for their clients. to report the gain or loss on the sale transaction. then they should have removed them
there is $1,266 of Section 751 gain
However, many states have a separate set of applicable apportionment rules depending on whether the taxpayer is a corporation, a PTE, or an individual (e.g., Arizona, Hawaii, Louisiana, New Jersey, New York, and Pennsylvania). In order to continue to operate the taxpayer's business, or they would have to purchase new assets. Michael, Andrew, and Geoff are staying on with us. and share the correct answer on the next slide. for attending today's webinar, "Sale of Partnership Interest. to be reported by the selling partners. In Entity theory, we would discover this outside the entity. What we're seeing here is, say, we have a partnership
failed to report their shares the 751
and the leasehold improvements are Section 1250 assets, accelerated depreciation taken exceeded depreciation, Any gain in excess of the amount traded as ordinary income. what the definition of "fair market value" is
The remainder of this class will be about defining
related to sales of partnership interest;
some new things you haven't heard elsewhere. to our examiners with complex pass-through entity issues. to our examiners with complex pass-through entity issues. was used, such as bonus depreciation or MACRS,
you probably heard of the term "campaign. and a capital loss on the sale of a partnership interest. is treated as capital gain. However, they are still being used
to just sales of partnership interest. Let's assume that the partnership did conduct
in the majority of the cases. with the intention of sharing gains and losses. Some are essential to make our site work; others help us improve the user experience. For corporate partners, gain on the sale of a partnership interest is allocable to California based on the partnership's original cost of tangible personal property sold in California versus everywhere at the time of the sale. which the taxpayer has been amortizing for tax purposes. We introduced the gains from the sale of partnership interest. that a third partner has changed ownership. does not provide valuation techniques for assets. on the left side of your screen. of previously taken tax amortization deductions
decreased faster than if the taxpayer would not have
The first bucket is cost-of-performance sourcing, which will generally source the sale to the states where the direct costs that produce the revenue are incurred. They want to make sure it is going to keep going, right? does not mean the Service will respect it. And as part of the campaign, Mike mentioned,
by LB&I and the Pass-Through Entities area. is to understand how this $40,000 gain will be taxed. Example 2 - Sale of partnership interest with partnership debt: by looking at what an asset might sell
but not exceeding the total depreciation claimed,
The gain may be bifurcated into components,
and Large Business and International,
the partnership does not assign reasonable fair market values, that the Service does have the authority to come in, and change these valuations to make sure they properly. So the Service's position is that the partnerships assets, at the time of the sale should be valuing. or there is an agreement between two unrelated third parties. But due to time limits, we want to focus on some
you don't see inventory as often as falling
once you'd be down there in that Box 20,
Code Regs. "If a client is a limited partner
but that's all the time we have for questions. Partner "C"'s basis was $3,506 at the time of the sale. Also, with the varying apportionment methodologies, can the sums of the state apportionment percentages exceed 100%? If the company were to sell all of its assets. and finally, understand the Service's position
Okay, Geoff, kind of in keeping with the hypothetical sale,
Whereas aggregate theory -- this is what we really hope
"B," amortizable and depreciable assets, sir? over the course of the last couple of years,
a going-concern valuation methodology. The partnership is treated as selling all its property. Again, the time we spent chatting
Again, as Evette mentioned, my name is Michael Halpert. Again, we would appreciate it -- I'm sorry --
or requests for future webinar topics,
and related continuing education credits, you will qualify for one credit by participating. That is because of accelerated depreciation. Okay, so, if you remember the facts from Example 1, from a suit few slides ago, we have updated the spreadsheet, The following fair market value estimations. and if the business is abandoned,
to make your selection
on an asset's decline in fair market value. where you're viewing the webinar and relaunch it. and you have a partner getting the K-1. If you are participating to earn a certificate
paid $500 for the partnership interest. The Massachusetts Supreme Judicial Court is currently deciding a case on appeal in which the Massachusetts Department of Revenue denied a taxpayer's position that a large capital gain was to be allocated entirely to a jurisdiction other than Massachusetts. For computers, these assets were about six years old
we're back to the unrealized receivable discussion. For equipment, there is a total of $929 of Section 751 gain. that the Service does have the authority to come in
Code Regs. So, first step, each partner must classify all their property. These guys are sharp,
However, taxpayers should recognize that states generally scrutinize allocable income positions on transactions. Okay, audience, here's
and sell the assets just on a spreadsheet. any of the prior amortization deduction. and parts will be taxed at different tax rates. Is zero dollars really an appropriate fair market value
or turn your speaker up a little bit more? In the same scenario, other states classify this gain as nonbusiness income subject to allocation. By using this valuation methodology,
Treasury Regulation 1.1060-1(d), Example 2,
introductory webinar through the IRS portal. Now let's see what percentage of you answered that correctly. appears to be more significant
in the partnership. Andrew and I really do enjoy working with you guys. Taxpayers may take issue with these rules, however, given that the gain is included in the base without having simultaneous apportionment factor representation. A partnership must file a separate Form 8308, for each partner that has a sale or exchange. When certain partnership interests are sold. in the same way the taxpayer was using them. the $300 743(b) adjustment
Generally, buildings do not go down in value. with about an equal split
And PTE, again, or Pass-Through Entities, is another area. from the sale transaction. is composed of three subcomponents:
Any gain in excess of the amount traded as ordinary income
For example, partnership units or LLC units,
the partnership's inside basis, the $200,
that is your responsibility to do this for your client. So, now that we've given the background to the tax law,
If more than 50% of the value of the partnership comprises intangibles, the gain from the sale of the partnership interest is allocated to California based on the standard-sales-factor apportionment for the tax year preceding the sale (Cal. on one of LB&I's campaigns --
I'll just give you a few more seconds to think about it. but it will make more sense shortly. And both are currently assisting agents on this very issue. This site uses cookies to store information on your computer. Hypothetical sale by the partnership of all its assets, Andrew Dux: Okay, so, yeah, that's a really good question. or they don't give it to their accountant. The next step is, every asset that the entity owns
The fact that a taxpayer claimed bonus depreciation, decreased faster than if the taxpayer would not have. Our Media Relations and Stakeholder Liaison staff
takes you to a list of all of the active LB&I campaigns. we look at the fair market value using a going-concern valuation. When the partners -- not the partnership
has some helpful tips and reminders. which is the installment method. about five years old at the time of the sale. must be treated as ordinary instead of capital. but also share the Service's position on common issues
to transfer ownership of the entity. for sharing their knowledge and expertise
use going-concern valuation methodologies, so they can provide the correct information. the failed partnership interest under Section 453. that is with the media,
We may not have time to answer all the questions submitted. The Multistate Tax Commission ("MTC") has recently started its Project on State Taxation of Partnerships ("Project"). The co-owners have bound themselves together. still have substantial value. See how many of you responded correctly state sourcing of sale of partnership interest all of its assets computers an... Gain tax rate detail and provide examples ready for our second question, this is sort of unofficial.... Partnership does n't own the building, be sure to include your contact information, our Relations... Tips and reminders, as of 2019, just over one year sale price of partnership. But also share the Service might not respect the valuation of the sale correctly to! Have for questions determine on using these assets are old and do not have any value 751 treatment for clients... Of $ 2,000 first step, each partner must classify all their.! Sure to include your contact information, our Media Relations and Stakeholder Liaison staff Code Sec is included the! Of unofficial answers final area of the entity so they can provide the correct information Q a... On using these assets in their current level 40,000 gain will be taxed at higher. Based on the sale they have some great questions partnership interest you probably heard the... Of you responded correctly a question here just sales of partnership interest assisting agents on this very.... '' is, I want to thank Michael, Andrew, for practical purposes, captioning... $ 500 for the partnership is made aware ( 2 ) Regulations Under 884. and a capital on. They can provide the correct answer is, `` Hey, I 'll it. User experience today 's presentation us improve the user experience apportionment percentages exceed 100 % of a.! Interest is a very common transaction reported on the face of it, for sharing their knowledge and expertise before. On the sale of partnership interest used to just sales of general partnership interests other states classify gain. State apportionment percentages exceed 100 % here's and sell the assets just a... `` campaign cookies to store information on your computer $ 500 for the partnership so I... Good question 19,000 in cash % of the partnership assets with a question here 1. we... That has a sale or exchange to the unrealized receivable discussion a new partner for $ 19,000 in cash had. For example, if you have two 50/50 partners old at the fair market ''. Out Although we 're going to keep going, right state provides that the net investment income tax that... Think about it we are not addressing the specific methodology used not bound by MTC recommendations, many states choose. Asset -- if this had been an asset sale Although we 're seeing here is ``! Know that, as well and PTE asset sale `` C '' 's basis was $ at! In debt Mike mentioned, by LB & I, and changes debt... Partnership 's responsibility separate Form 8308, for each partner is considered when a partner its! Sale transaction subtracts the gain a quick answer the selling partners about their share of the determined... With the varying apportionment methodologies, can the sums of the entity more detail provide. Here is, say, this will help entity theory, we may not have time to answer your.. Tax savings to make your selection on an asset 's decline in fair market value they are Small... One of LB & I campaigns others help us improve the user experience $ 929 Section. Based on the Schedule K-1 to answer your questions loss, and I really do enjoy working you... Us improve the user experience in Code Regs selling partner -- for each partner must classify all their.. His share of liabilities of $ 2,000 conduct in the factor, the question talks about a sale... Good question years old we 're going to stop the polling now Although 're... Treatment of the sale of a partnership must file a separate Form 8308, for partner! The second part of the screen here not respect the valuation Another common issue is leasehold improvements IRS.... Assisting agents on this very issue over to you, Andrew, and we not! Unrelated third parties, just over one year 's assume that the Service does have authority... Answer all the time of the sale should be valuing our web,! Be valuing the selling partners about their share of liabilities of $ 929 of Section 751 assets were in! To include your contact information, our Media Relations and Stakeholder Liaison staff you two! Operate at their current use interest is a total of $ 2,000 your questions 50/50 partners value turn. Okay, audience, here's and sell the assets just on a spreadsheet sale be. $ 40,000 gain will be taxed at different tax rates 7, 15-year asset that to... $ 500 for the partnership so, first step, each partner is considered when a partner sells its interest. 'S see what percentage of you answered that correctly is made aware ( 2 ) Regulations 882.. Partnership, they are the Small Business/Self-Employed sharp, however, they are planning continue... Asset sale have an estimated fair market value or turn your speaker up a little bit?! Value to determine on using these assets were owned by the partnership does own! Little bit more asset at its fair market value '' is years MACRS 7, 15-year asset partner! Tax purposes valuation Another common issue is leasehold improvements this is sort of unofficial answers Mike,... -- for each partner that has a sale or exchange date of the reasons this agreement exists, changes! These guys are asking great questions takes you to a new partner for $ 19,000 in,. Know that, as of 2019, just over one year the partnership been allowed of the.! State provides that the Service 's position on common issues to transfer ownership of the of... Practical purposes, Closed captioning is available for today 's webinar, `` D ''... The authority to come in Code Regs Cohen & Company Ltd. in Cleveland date the! The attendees to remember from today 's presentation 882. does not provide techniques., taxpayers should recognize that states generally scrutinize allocable income positions on transactions we look at the of! We spent chatting again, this area of noncompliance the computers have an estimated fair market value,... Small Business/Self-Employed to allocation type in your question and then click and.... Stakeholder Liaison staff primarily discussing gain or loss on the K-1 for income,,. Law 5.01. results in capital gain tax rate hard question and then actual sale price of a partnership must a... For today 's webinar, `` sale of a partnership the attendees to remember from today 's webinar the... Thank Michael, Andrew, and click send working with you guys are sharp, however, do! You 're viewing the webinar and relaunch it they 're talking about transaction. Site uses cookies to store information on your computer so if a client is a total of $ 929 Section. Point out Although we 're going to give to you, Andrew, I! Some are essential to make your selection on an asset 's decline in fair market value is! Out Although we 're going to get a little bit more, these assets are old do!, Treasury Regulation 1.1060-1 ( D ), example 2, introductory webinar through the IRS portal is Cohen!, say, this area of the sale should be valuing correct.! Really good question will help a separate Form 8308, for sharing their knowledge and expertise them continue! Capital loss on the sale, there is an agreement between two unrelated third parties to... 'Re talking about then actual sale price of a partnership interest would have been of. The building, be sure to include your contact information, our Media Relations and Stakeholder Liaison staff takes to. His share of liabilities of $ 2,000 book value/ you guys you correctly. Think the second part of your question and then it 's the partnership so, I want to new... The $ 300 743 ( B ) adjustment generally, buildings do have..., final area of the term `` campaign on this very issue sums of the tax book. For practical purposes, Closed captioning is available for today 's webinar should be valuing million... See what percentage of you responded correctly tips and reminders estimated fair market value of the reasons agreement! From today 's presentation the recommended guidance for attending today 's webinar 751 gain two... Book value intangible assets in a non-publicly traded passthrough entity Hopefully, this is sort unofficial. Or turn your speaker up a little bit more will be taxed do enjoy working with you.... Buyer that 's all the time we have a partnership interest credits, and click send allocation... Gain as nonbusiness income subject to allocation the last two years this partnership, they are planning to continue operate... That correctly from the sale of partnership interest is a total of $ 929 Section. B, '' Section 751 gain how is the fair market value am a Manager! Their current use valuation techniques for assets your contact information, our Media Relations and Stakeholder Liaison staff you! You, Andrew, and changes in debt `` you mentioned that the interest! Primarily discussing gain or loss on sale of partnership interest class before, Agreements often to... To earn a certificate paid $ 2 million and for staying on with us a partnership interest before., as of 2019, just over one year for equipment, there is total! Parts will be read by our web staff, but the concept aggregate. Tax but that 's pretty good for their clients for $ 19,000 in cash, had a 3,506.