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You are essentially liquidating an S corporation and starting a new entity. 

 

I will page @Rick19744 for input, but you might also want to seek in-person guidance from a local tax professional.

 

There is a way for corporations to do this on a tax-free basis (of which @Rick19744 can add input also), but it would probably be too late to rectify any missteps since the deal was done over a year ago.

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