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kpmg exhibits - 53
This form, from KPMG's Tax Innovation Center, demonstrates how the firm solicited its employees to submit tax shelter ideas.

Tax Innovation Center

Product Idea Submission Form

Submit to: "US TAXBOT PRODUCTS" Outlook mailbox.

From (Idea Submitter): Lany Manth, Andrew Atkin, Douglas Duncan, and Robert Huber

Office: Los Angeles

Suggested idea name/brief description: S-Corporation Charitable Contribution and Estate Planning Strategy ("S-CAEPS")

Date submitted: January 31, 2000

Check primary product group: X Federal _ PFP _ SALT _ IES _ IS

Identify other affected product groups: PFP

This Product Idea Submission Form is designed to assist in technical and market screening and prioritizing the development of new product ideas. The submitter may need to spend 3 to 8 hours of due diligence on a new idea before submitting this form.

1. Please explain the idea in detail, including how client savings are achieved:

See Attached Memo

2. What do you believe are the tax, business, and financial statement benefits of the idea (please list using bullets):

* Tax Elimination, conversion, and deferral

* Enhanced cash flow

* Philanthropic benefits

3. Please list the trans.action steps (if applicable):

See Attached Memo

4. Please include/attach a schematic of the idea (if applicable):


exhibit 53
examine a facsimile of this document

5. To which tax jurisdictions (countries, states) do you believe the idea applies?

Federal and all states (this is an S-corporation idea)

6. Please summarize any federal, state, and foreign tax technical support. (If possible, list the applicable cites that support the idea's technical premise. Please attach related technical memoranda already produced.)

See Attached Memo

7. Please list any unresolved tax issues of which you are aware:

See Attached Memo

8. If the strategy has been delivered to a client, please attach copies of client deliverables (memos, excel spreadsheet, etc.).

We completed two transactions by 12/31/99 and have not yet finalized the deliverables

9. Please help us detetmine whether this idea wm meet the Tax Product Development Revenue Threshold by providing the following, to the extent you can:

  1. List the optimal target characteristics:

S corporations with taxable income> $2 million and less than 5 shareholders

  1. List the key target markets:

All large cities

  1. Identify the typical buyer (e.g., CEO, CFO, Tax Director):


  1. Estimate an average tax fee per engagement for this idea:

Minimum fee of $300,000 (the projects we completed had an average fee of approximately $600,000).

THANK YOU for taking the time to submit your idea.



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posted february 19, 2004

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