Walter Skip Ebel III Blake D. Lewis

1. www.FridayFirm.com
Tax Update Seminar
November 13, 2019
Walter (Skip) Ebel III
Blake D. Lewis
The Technical side of 199A Qualified
Business Income Deduction

2. www.FridayFirm.com
Section
199A
Deduction
Taxpayers, other than corporations, are
generally eligible to claim a deduction equal
to the lesser of:
- The taxpayer’s combined qualified business
income (CQBI) amount, or
- 20% of the taxpayer’s taxable income in excess of
capital gain.

3. www.FridayFirm.com
Combined
Qualified
Business
Income
The sum of:
- 20% of the taxpayer’s qualified business income
(QBI) with respect to each qualified trade or
business (QTB), and
- 20% of the aggregate amount of qualified REIT
dividends and qualified publicly traded partnership
income.

4. www.FridayFirm.com
General Definitions
Qualified Business Income:
- The net amount of qualified
items of income, gain,
deductions, and loss from a
QTB of the taxpayer within the
United States.
Qualified Trade or Business:
- Any trade or business other than
a specified service trade or
business (SSTB), or the trade or
business of performing services
as an employee.

5. www.FridayFirm.com
Items Included in QBI
- Gains treated as ordinary
income under § 751(a) or
751(b)
- § 481 adjustments, provided
that the method change was
made for a taxable year
ending after December 31,
2017
- Interest income received on
accounts or notes receivable
for services or goods
provided by the trade or
business
- Partnership’s deductions for
guaranteed payments paid to
a partner for services under
§§ 707(a) & 707(c)
- Net operating losses that
were previously disallowed
under § 461(l)

6. www.FridayFirm.com
QBI Does Not Include:
- Capital gains and losses,
including any item treated as
such items, including § 1231
gains or losses
- Interest income not allocable to
a trade or business
- Reasonable compensation
received by an S corporation
shareholder
- Guaranteed payments
described in § 707(c) paid to a
partner for services
- § 707(a) payments received by
a partner for services rendered
with respect to the trade or
business
- Investment income
- Income received from
performing services as an
employee
- NOLs other than NOLs
previously disallowed under
461(l)

7. www.FridayFirm.com
What is a
trade or
business?
Regulations explain that generally a trade
or business for purposes of § 199A is
defined as a trade or business within the
meaning of § 162.

8. www.FridayFirm.com
Rental Real Estate Safe Harbor
Requirements to qualify:
- Separate books and records are maintained to reflect income and
expenses for each rental real estate enterprise.
- At least 250 hours of rental services must be performed per year with
respect to each rental enterprise.
- If enterprise has been in existence for more than 4 years, this
requirement must be satisfied for 3 of the pervious 5 years.

9. www.FridayFirm.com
Rental Real Estate Safe Harbor
- The taxpayer must maintain contemporaneous records, including time
reports, logs, or similar documents, regarding (i) hours of all services
performed, (ii) description of all services performed; (iii) dates on which
such services were preformed; and (iv) who performed the services.
- The taxpayer or RPE attaches a statement to a timely filed original tax
return for each taxable year in which the taxpayer or RPE relies on the
safe harbor.

10. www.FridayFirm.com
Not Included in Safe Harbor
- Real estate used by the taxpayer (including an owner
or beneficiary of an RPE) as a residence under
section 280A(d).
- Real estate rented or leased under a triple net lease.
- Real estate rented to a trade or business conducted
by a taxpayer or an RPE which is commonly controlled
under 1.199A-4(b)(1)(i).
- The entire rental real estate interest if any portion of
the interest is treated as an SSTB.

11. www.FridayFirm.com
- Two requirements:
- (i) Regular and continuous conduct of the activity, which depends on
the extent of the taxpayer’s activities; and
- (ii) Profit motive—good faith intention to make a profit from the activity.
- Tax Court has consistently found the existence of trade or
business when only a small amount of rental activity is present,
such as holding a single property out for rental and collecting
rent.
- See e.g., Lagreide v. Comm’r, 23 T.C. 508 (1954); and Hazard v.
Comm’r, 7 T.C. 372 (1946);
Real Estate Trade or Business
Under Case Law

12. www.FridayFirm.com
Multiple Trades or Businesses
Items of QBI which are “properly attributable” to more than one
trade or business operated by an individual or single entity must
be allocated among the trades or businesses using a reasonable
method based on all the facts and circumstances

13. www.FridayFirm.com
Aggregation of Businesses
- Individuals and RPEs are allowed to aggregate multiple QTBs
provided certain requirements are met.
- RPEs may aggregate QTBs it operates directly or indirectly
through lower-tier RPEs.
- An individual or lower-tier RPE may not separate the
aggregated QTBs, but an individual or upper-tier RPE may
aggregate additional QTBs.
- The resulting aggregation must be reported by the RPE and
each of the owners.

14. www.FridayFirm.com
Aggregation Requirements
- The same person, or group of persons, must, directly or
indirectly (attribution under 267(b) or 707(b), own 50% of each
business to be aggregated
- Majority ownership must exist for a majority of the taxable year,
including the last day of the taxable year.
- Each QTB has the same taxable year.
- No QTB can be an SSTB.
- And . . . .

15. www.FridayFirm.com
Aggregation Requirements
The QTB’s to be aggregated satisfy 2/3 of the following:
- The businesses provide products and services that are the same or
they provide products and services that are customarily provided
together;
- The businesses share facilities or share significant centralized business
elements; or
- The businesses are operated in coordination with, or reliance on, other
businesses in the aggregated group.

16. www.FridayFirm.com
If a taxpayer’s taxable income is at least $157,500 ($315,000 in
the case of a joint return) QBI for each QTB is limited to the
lesser of:
- 20% of the taxpayer’s QBI with the respect to the QTB; or
- The greater of
- 50% of the W-2 wages with respect to the QTB, or
- The sum of 25% of the W-2 wages with respect to the QTB, plus
2.5% of the unadjusted basis immediately after acquisition (UBIA) of
all qualified property.
W-2 Wages and Qualified
Property Limitation

17. www.FridayFirm.com
W-2 Wages
and
Qualified
Property
Limitation –
Phase-in
The wage and property limitation phases in
for taxpayers with taxable income not in
excess $207,500 ($415,000 in the case of a
joint return).

18. www.FridayFirm.com
Definition of
W-2 Wages
W-2 wages include the total amount of
wages defined in § 3401(a) plus the total
amount of elective deferrals (within the
meaning of §402(g)(3)), the compensation
deferred under § 457, and the amount of
designated Roth contributions.

19. www.FridayFirm.com
A person may take into account any W-2 wages paid by another
person and reported by the other person on Forms W-2 with the
other person listed as the employer, provided that the W-2
wages were paid to common law employees or officers of the
individual or pass-through entity for employment by the
individual or pass-through entity.
Management Company Exception

20. www.FridayFirm.com
W-2 Wages – Properly Allocable
Rule: W-2 wages only include amounts that are “properly
allocable” to QBI
Three step process for determining if W-2 wages are “properly
allocable” to QBI.
- Each individual or pass-through entity must determine its total W-2 wages
for the taxable year.
- Each individual or pass-through entity must allocate its W-2 wages
between or among one or more trades or businesses.
- Each individual or pass-through entity must determine the amount of such
wages with respect to each trade or business that are allocable to QBI of
the trade or business.

21. www.FridayFirm.com
Methods for Calculating W-2 Wages
Unmodified Box Method.
- The lesser of Boxes 1 and 5 for all employees’ W-2 forms.
- This is the simplest approach, but may result in a lower number than
other approaches.
Modified Box 1 Method.
- Box 1 less some amounts that are not wages for withholding purposes
and totals in Box 12, Code D, E, F, G, and S relating to elective deferrals.
Tracking Wages Method.
- All wages subject to withhold and totals in Box 12, Code D, E, F, G, and S
relating to elective deferrals

22. www.FridayFirm.com
Qualified Property
Qualified Property must satisfy the following criteria:
- Tangible property and have an allowance for depreciation under § 167,
- Held by, and available for use in, a qualified trade or business at the close
of the taxable year,
- Used in the production of QBI during the taxable year, and
- The depreciable period cannot have ended before the close of the
taxable year (from placement in service to shorter of 10th anniversary or
the § 168 recovery period).

23. www.FridayFirm.com
Qualified Property
Property is not qualified property if acquired
within 60 days of the end of the taxable year
and disposed of within 120 days, without
being used in the trade or business for at
least 45 days.
Anti Abuse Rule

24. www.FridayFirm.com
UBIA of Qualified Property
In general:
- Cost basis under § 1012
Inherited property:
- FMV under § 1014
Property contributed to an S corporation or partnership:
- The entity’s UBIA will be the same as the transferor’s UBIA in the
property, decreased by the amount of money received by the transferee
in the transaction or increased by the amount of money paid by the
transferee to acquire the property in the transaction.

25. www.FridayFirm.com
The later of:
- 10 years after placed in service date, or
- The last day of the last full year in the applicable recovery period under §
168 (without regarded to section § 168(g))
Depreciable Period of Qualified
Property

26. www.FridayFirm.com
Placed in Service Date:
- Replacement property has the same placed in service date as
relinquished property.
- Exception: Placed in service date for any excess basis will be the date
the replacement property was fist placed in service.
UBIA:
- Based on the transferee’s unadjusted basis in the relinquished property,
but decreased by excess boot or increased by the amount of money paid
or fair market value of property not of a like kind to the relinquished
property.
Depreciable Period §1031
Exchanges/ §1033 Conversions

27. www.FridayFirm.com
Depreciable Period
Improvements are treated as separate
qualified property first placed in service
on the date such improvement is
placed in service.
Improvements to
Qualified Property

28. www.FridayFirm.com
General Rule:
- Each equity holder’s share of UBIA is an amount that bears the same
proportion to the total UBIA as the equity holder’s share of tax
depreciation bears to the entity’s total depreciation attributable to the
property for the year.
If the property does not produce tax depreciation during the
year:
- Partnership: each partner’s share of the UBIA is based on how gain
would be allocated under § 704 in a hypothetical sale.
- S Corporation: each shareholder’s share of UBIA is based on the
shareholder’s ownership percentage of the corporation.
Allocation of UBIA of Qualified Property
Among Shareholders and Partners

29. www.FridayFirm.com
Specified Service Trade or Business
Eligibility for the § 199A deduction requires a taxpayer to have
qualified business income:
- Qualified Business Income: The net amount of income, gain, deductions,
and loss from a QTB, within the United States.
- Qualified Trade or Business: Any trade or business other than an SSTB
or the trade or business of performing services as an employee.

30. www.FridayFirm.com
Specified Service Trade or Business
General Rule:
- If a trade or business is an SSTB, no QBI, W-2 wages, or UBIA of
qualified property from the SSTB may be taken into account by a
taxpayer in determining the taxpayer’s § 199A deduction.
Exception:
- If a taxpayer’s income taxable income is less than $157,500 ($315,000 in
the case of joint return) (the “Threshold Amount”), the SSTB limitation
does not apply.
- If a taxpayer’s income is greater than the Threshold Amount but less than
$207,500 ($415,00 in the case of a joint return), the SSTB limitation is
phased-in.

31. www.FridayFirm.com
Specified
Trade or
Service
Business
Health
Financial Services
Accounting
Actuarial Science
Performing Arts
Consulting
Athletics
Law
Brokerage
Securities,
Commodities,
Partnership
Interests
Reputation
or Skill
Investment
Management

32. www.FridayFirm.com
Guidance from the Final Regulations
QTB
- Architecture or engineering
services
- Broadcasting or disseminating
video or audio of professional
sports or performing arts
- Retail banking, including taking
deposits or making loans
- Insurance brokerage
- Payment processing & billing
services
- Real property management
- Pharmaceuticals or medical
devices
- Operators of emergency care
centers, urgent care, surgical
centers
- Lab services with no proximity to
patients
- Health clubs & spas
- Consulting that is embedded or
ancillary to the sale of goods.

33. www.FridayFirm.com
Guidance from the Final Regulations
SSTB
- Stock brokerage
- Medical services, including those
not directly provided to patients
- Pharmacist providing medical
services
- Consulting services
- Investment banking
- Veterinary services
- Financial services, including
arranging and lending
transactions
- Dealing in securities,
commodities or partnership
interests
- Investment management
- Sports teams

34. www.FridayFirm.com
Healthcare - Does not include the operation of health
clubs or health spas that provide physical
exercise or conditioning to their customers,
payment processing, or the research,
testing, and manufacture and/or sales of
pharmaceuticals or medical devices.
- The examples in the regulations explain
that surgery centers are not SSTBs;
however, the examples indicate that the
employment of healthcare professional or
the collection of income from healthcare
professional in connection with the surgery
center would change this result.

35. www.FridayFirm.com
Consulting - Does not include the performing consulting
services embedded in, or ancillary to, the
sale of goods or performance of services
on behalf of a trade or business that is
otherwise not an SSTB if there is no
separate payment for the consulting
services.
- If consulting services result in less than
10% of the gross revenue of a business,
the business will not be considered an
SSTB.

36. www.FridayFirm.com
Specified
Trade or
Service
Business
De Minimis Rule:
- If a trade or business has gross receipts of no
more than $25 million and less than 10% of its
gross receipts are attributable to the performance
of services in an SSTB, it is not an SSTB.
- If a trade or business has gross receipts greater
than $25 million, it is not an SSTB if less than 5%
of the its gross receipts are attributable to the
performance of services in an SSTB.

37. www.FridayFirm.com
SSTB Anti-Abuse
Services or Property Provided to an SSTB:
- If a trade or business provides property or services to an SSTB and there
is 50% or more common ownership of the trades or businesses, that
portion of the trade or business of providing property or services to the
50% or more commonly-owned SSTB will be treated as a separate SSTB
with respect to the related parties.
50% or more common ownership includes direct or indirect
ownership by related parties within the meaning of § § 267(b) or
707(b).

38. www.FridayFirm.com
Calculating the Deduction
The deduction is equal to the lesser of:
- 20% of the total QBI amount (the “QBI Component”), plus 20% of the
combined amount of qualified REIT dividends and qualified publicly
traded partnership income, or
- 20% of the individual’s taxable income (in excess of net capital gain).

39. www.FridayFirm.com
For individuals with taxable income below the income threshold,
$157,500 ($315,000 in the case of a joint return), the QBI
Component is simply the net total QBI from all QTBs and
SSTBs.
Determining the QBI Component –
Individuals Below Income Threshold

40. www.FridayFirm.com
For individuals with taxable income above the Threshold
Amount, the QBI Component is determined by taking the
following steps:
Determining the QBI Component –
Individuals Above Income Threshold

41. www.FridayFirm.com
Step 1
Determining the
QBI component
–
Individuals
above Income
Threshold
- 1-A: Determine QBI for each QTB and, in
the case of a taxpayer within the phase-in
range, each SSTB.
- 1-B: If a taxpayer is within the phase-in
range, the “applicable percentage” must be
calculated that limits the QBI, W-2 wages
and UBIA of qualified property from the
SSTB.
- “Applicable Percentage” means 100% reduced
by the percentage equal to the ratio that the
taxable income of the individual for the taxable
year in excess of the threshold amount bears to
$50,000 ($100,000 if joint return).

42. www.FridayFirm.com
Step 2
Determining the
QBI
Component –
Individuals
above Income
Threshold
Net QBI from all trades or businesses
- If QBI from one or more trade or business is negative
and QBI from one or more trade or business is positive,
the negative amount offsets QBI attributable to each
QTB that produced positive net income in proportion to
the relative amounts of QBI in the trades or businesses
with positive QBI.
- The W-2 wages and UBIA of qualified property from
the trades or business which produced net negative
QBI are not taken into account in calculating the W-2
wages and UBIA of qualified property.
- If an individual’s combined QBI is negative, the
negative amount is carried forward to the succeeding
year. This rule does not affect the deductibility of the
loss for purposes of other provisions of the Code.

43. www.FridayFirm.com
Step 3
Determining the
QBI
Component –
Individuals
above Income
Threshold
Determine the “deductible amount” for each
QTB and, in the case of a taxpayer within the
phase-in range, SSTB
- Deductible amount is equal to the lesser of
- 20% of the taxpayer’s QBI with the respect to the
QTB; or
- The greater of
- 50% of the W-2 wages with respect to the QTB,
or
- The sum of 25% of the W-2 wages with respect
to the QTB, plus 2.5% of the unadjusted basis
immediately after acquisition (“UBIA”) of all
qualified property.
Note: Combine QBI, W-2 wages and UBIA of
qualified property for aggregated trades or
businesses before applying limitation.

44. www.FridayFirm.com
Step 3 cont.
Determining the
QBI
Component –
Individuals
above Income
Threshold
Special rule for the wage and property
limitation for individual in phase-in range.
- If the individual is within the phase-in range and
the amount of wage or property limitation for a
trade or business is less than 20% of the QBI for
such business, then the QBI component for such
trade or business must be reduced.
- The reduction is equal to (1) 20% of the taxpayer’s
QBI from the QTB (determined without regard to
this rule) minus (2) the Excess Amount multiplied
by (A) the amount by which the taxpayer’s taxable
income for the tax year exceeds the threshold
amount, divided by (B) $50,000 ($100,00 in the
case of a joint return).
- The Excess Amount is 20% of QBI over the
greater of 50% of W-2 Wages or the sum of 25%
of W-2 wages plus 2.5% of the UBIA of qualified
property.

45. www.FridayFirm.com
Reporting Requirements
The following information must be provided by the pass-through
entity for each trade or business it directly engages in:
- Each owner’s allocable share of QBI, W-2 wages, and UBIA
- Whether any of the trades or businesses are SSTBs
If a pass-through entity owns a direct or indirect interest in a
pass-through entity it must also report the QBI, W-2 wages,
UBIA, and SSTB status on the K-1 for those lower tier entities.

46. www.FridayFirm.com
PANEL DISCUSSION
Walter (Skip) M. Ebel III
Price C. Gardner
Robert T. Smith
Blake D. Lewis
Untangling Tax Reform – A Panel Discussion on
199A Qualified Business Income Deduction

47. www.FridayFirm.com
Choice of
Entity
Considerations
Advantages:
- One layer of tax
- Ability to make special allocations
- Easy to convert to a corporation
- Estate Tax Planning benefits through use of
GRATs and IDITs
Disadvantages:
- QBI deduction expires in 2025
- Complex
- SE Tax
- Few deductible fringe benefits
PARTNERSHIPS

48. www.FridayFirm.com
Choice of
Entity
Considerations
Advantages:
- Ability to deduct fringe benefits
- § 1202 treatment
Disadvantages:
- Two layers of tax
- NOL can only offset corporate income
- Accumulated earnings tax
C
CORPORATIONS

49. www.FridayFirm.com
Choice of
Entity
Considerations
Advantages:
- One layer of tax
- Income not subject to SE tax
- Estate Tax Planning benefits through use of
GRATs and IDITs
Disadvantages:
- Single class of stock requirements
- Limitations on types of shareholders
- Highest marginal tax rate for shareholders is
higher than for C corporation shareholders
S
CORPORATIONS

50. www.FridayFirm.com
Real Estate Example
Activity 3:
Bren owns 50% of Partnership C that
owns Property C, a convenience store
it leases under terms disqualifying the
relationship as a NNN lease. Bren is a
passive investor in the partnership.
Activity 4:
Bren owns 30% of Partnership D that
owns Property D, a 60% residential/
30% commercial mixed use office
building. Alex spends 100 hours/year
managing Property D.
Activity 1 & 2:
Bren personally owns Property A and
Property B that are held out for rent as
residential rental property. Bren spends
200 hours per property, per year,
performing real estate services.
Bren owns interest in five real estate activities.
Activity 5:
Bren owns 5% of a partnership that
owns Property E, a commercial office
building. Property E is rented under a
NNN lease.

51. www.FridayFirm.com
Real Estate Example Analysis
Bren may choose to treat each property as a separate rental real
estate enterprise.
- If he does this, the safe harbor would not be available to him with respect
to any of the properties he owns individually, Property A and Property B,
because he does not meet the 250 hour requirement for either Property A
or Property B, but he may be able to argue trade or business under
relevant case law.

52. www.FridayFirm.com
Real Estate Example Analysis
- Bren may aggregate Properties A and B because he owns them directly
and both properties are residential. In which case, he would qualify for the
safe harbor because he spends more than 250 hours of service with
respect to the properties.
- The safe harbor is irrelevant to Bren as to Properties C, D, and E
because he does not own the property outright or through a disregarded
entity.
- If Partnership C performs 250 hours either directly or through
independent contractors, such as a property management company,
Partnership C may qualify for the safe harbor, in which case Bren’s
allocation of income would be QBI.

53. www.FridayFirm.com
Real Estate Analysis Continued
- Partnership D can either treat the mixed-use property as a single
enterprise or as two separate enterprise (one commercial and one
residential). Whether Bren’s allocation of income from Partnership D is
QBI will be based on whether Partnership D enterprises are trade or
businesses under § 162.
- Property E is leased under a NNN lease; therefore, Partnership E will not
qualify for the safe harbor. Therefore, whether Bren’s allocation of income
from Partnership E is QBI will be based on existing jurisprudence under
§ 162.

54. www.FridayFirm.com
Aggregation Example
- A, B, C, & D collectively own a 60% interest in four
partnerships (PRS1, PRS2, PRS3 and PRS4) for the entirety
of 2018. Each partnership operates a hardware store.
- A team of executives oversees the operations of all four of the
businesses and controls the policy decisions involving the
business as a whole. Human resources and accounting are
centralized for the four businesses.
- The partners report PRS1, PRS2, and PRS3 as an aggregated
trade or business and reports PRS4 as a separate trade or
business. Only PRS4 generates a net taxable loss.

55. www.FridayFirm.com
Aggregation Example Analysis
The partners decision to aggregate only PRS1, PRS2, and PRS3 is
permissible because:
- A, B, C, and D collectively owned more than 50% of each partnership for the
majority of the taxable year, including the last day of the taxable year;
- Each partnership operates a hardware store; and
- Each partnership shares accounting and human resources functions.
- The loss from PRS4 will be netted against the aggregate profits of PRS1,
PRS2 and PRS 3.

56. www.FridayFirm.com
STTB Examples
Example 1
- Veterinarians A, B, C and D
each own 25% of Veterinarian
Practice ABCD in which they
all practice, and 25% of
Management Co. V that
provides services exclusive to
Veterinarian Practice ABCD.
Result 1
- Management Co. V is an
SSTB
Example 2
- Each veterinarian owns 100%
of his own practice and 25% of
Management Co. V, which
provides services exclusive to
each of the four veterinarian
practices.
Result 2
- Management Co. V is not an
SSTB.

57. www.FridayFirm.com
STTB Examples
Example 3.
- Veterinarians A, B, C and D each own 25% of a partnership in which they
all practice. In addition to the provision of veterinarian services, the
partnership also develops and sells organic dog food. The veterinarian
services gross receipts of $250,000 represents more than 10% of the $2
million gross receipts of the partnership, so the entirety of the
partnership’s trade or business is considered an SSTB.

58. www.FridayFirm.com
SSTB Examples
Example 4.
- Same facts as Example 3 except for the partnership separately invoices
and keeps separate books and records for veterinarian and sales
activities, has separate employees unaffiliated with the veterinarian clinic
that work on the dog food products, and treats the veterinarian practice
and dog food development and sales s separate trades or business for
purposes of §§ 162 and 199A. Even though more than 10% of the
partnerships gross receipts is from the veterinarian activity, the dog food
business is not considered an SSTB because the veterinarian practice
and the dog food business are separate trades or business under § 162.

59. www.FridayFirm.com
www.FridayFirm.com
400 West Capitol Ave. Suite 2000 I Little Rock, AR 72201
3425 North Futrall Dr. Suite 103 I Fayetteville, AR 72703
3350 South Pinnacle Hills Pkwy. Suite 301 I Rogers, AR 72758
PRICE C. GARDNER
Mergers & Acquisitions
501-370-1543
gardner@fridayfirm.com
www.fridayfirm.com/attorney/gardner

60. www.FridayFirm.com
www.FridayFirm.com
400 West Capitol Ave. Suite 2000 I Little Rock, AR 72201
3425 North Futrall Dr. Suite 103 I Fayetteville, AR 72703
3350 South Pinnacle Hills Pkwy. Suite 301 I Rogers, AR 72758
WALTER (SKIP) M. EBEL III
Mergers & Acquisitions
501-370-1557
ebel@fridayfirm.com
www.fridayfirm.com/attorney/ebel

61. www.FridayFirm.com
www.FridayFirm.com
400 West Capitol Ave. Suite 2000 I Little Rock, AR 72201
3425 North Futrall Dr. Suite 103 I Fayetteville, AR 72703
3350 South Pinnacle Hills Pkwy. Suite 301 I Rogers, AR 72758
ROBERT T. SMITH
Finance & Commercial Transactions
501-370-1559
rsmith@fridayfirm.com
www.fridayfirm.com/attorney/rsmith

62. www.FridayFirm.com
www.FridayFirm.com
400 West Capitol Ave. Suite 2000 I Little Rock, AR 72201
3425 North Futrall Dr. Suite 103 I Fayetteville, AR 72703
3350 South Pinnacle Hills Pkwy. Suite 301 I Rogers, AR 72758
BLAKE D. LEWIS
Mergers & Acquisitions
501-370-3341
blewis@fridayfirm.com
www.fridayfirm.com/attorney/blewis