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@Rick19744  and @tagteam 

Thank you so much for this feedback.  Yes I will consult with a tax professional if needed but am trying to get a grip on the general concepts first.

 

1. There was no election to be taxed as an association or corporation etc.  Just the default.

2.  ABC LLC held no physical assets.   ABC LLC held inherent copyrights (not registered yet, but given to the LLC in a contract) to educational booklets.

 

I will look at Revenue Ruling 99-5 and Section 1245...

 

Thank you!