Legal Question in Tax Law in New York

Your question requires the review of the stock purchase agreement to determine how the non-vested, 50% of the stock, is characterized and therefore cannot be answered without such a review.

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IRS CIRCULAR 230 DISCLOSURE: To ensure compliance with requirements imposed by the IRS, we inform you that any tax advice contained in this communication (including any attachments) was not intended or written to be used, and cannot be used, for the purpose of (i) avoiding tax-related penalties under the Internal Revenue Code or (ii) promoting, marketing or recommending to another party any matters addressed herein.