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Question: RadioCo, a domestic corporation, owns 100% of


RadioCo, a domestic corporation, owns 100% of TVCo, a manufacturing facility in the European country Adagio. TVCo has no operations or activities in the United States. The U.S. tax rate is 35%, and the Adagio tax rate is 15%. For the current year, RadioCo earns $200,000 in taxable income from its U.S. operations. TVCo earns $800,000 in taxable income from its operations, pays $120,000 in taxes to Adagio, and makes no distributions to RadioCo. Determine RadioCo’s effective tax rate for book purposes with and without the permanent reinvestment assumption of ASC 740-30 (APB 23).


> World Company expects to operate at 80% of its productive capacity of 50,000 units per month. At this planned level, the company expects to use 25,000 standard hours of direct labor. Overhead is allocated to products using a predetermined standard rate b

> Walker Company prepares monthly budgets. The current budget plans for a September ending inventory of 30,000 units. Company policy is to end each month with merchandise inventory equal to a specified percent of budgeted sales for the following month. Bud

> What two common benchmarks can be used to evaluate actual performance? Which of the two is generally more useful?

> How could information systems be used to support the order fulfillment process illustrated in Figure 2.2? What are the most important pieces of information these systems should capture? Explain your answer.

> Look in your medicine cabinet. No matter where you live in the world odds are that you'll find many Procter & Gamble (P&G) products that you use every day. P&G is the largest manufacturer of consumer products in the world and one of the top 10 largest co

> If you haven't heard of Valero don't worry. It's largely unknown to the public, although investors recognize it as one of the largest oil refiners in the United States. Valero Energy is a top-10 Fortune company headquartered in San Antonio, Texas, with 2

> How are information systems transforming business and what is their relationship to globalization? 1. Describe how information systems have changed the way businesses operate and their products and services. 2. Describe the challenges and opportunities o

> Snyders of Hanover, which sells about 80 million bags of pretzels, snack chips, and organic snack items each year, had its financial department use spreadsheets and manual processes for much of its data gathering and reporting. Hanover’s financial analys

> How will information systems affect business careers and what information system skills and knowledge are essential? 1. Describe the role of information systems in careers in accounting, finance, marketing, management, and operations management and expla

> What are the implications of globalization when you have to look for a job? What can you do to prepare yourself for competing in a globalized business environment? How would knowledge of information systems help you compete?

> What is the role of the information systems function in a business? 1. Describe how the information systems function supports a business. 2. Compare the roles played by programmers, systems analysts, information systems managers, the chief information of

> How will a four-step method for business problem solving help you solve information system-related problems? 1. List and describe each of the four steps for solving business problems. 2. Give some examples of people, organizational, and technology proble

> Why are systems for collaboration and teamwork so important and what technologies do they use? 1. Define collaboration and teamwork and explain why they have become so important in business today. 2. List and describe the business benefits of collaborati

> Identify some of the people, organizational, and technology issues that UPS had to address when creating its successful information systems.

> How do systems that link the enterprise improve organizational performance? 1. Explain how enterprise applications improve organizational performance. 2. Define enterprise systems, supply chain management systems, customer relationship management systems

> How might the BMW Oracle team have used collaboration systems to improve the design and performance of the America’s Cup sailboat USA? Which system features would be the most important for these tasks?

> What exactly is an information system? How does it work? What are its people, organization and technology components? 1. List and describe the organizational, people, and technology dimensions of information systems. 2. Define an information system and

> Can you run your company from the palm of your hand? Perhaps not entirely, but there are many functions today that can be performed using an iPhone, iPad, BlackBerry, or other mobile handheld device. The BlackBerry has been the favorite mobile handheld f

> How do systems serve the various levels of management in a business? 1. Describe the characteristics of transaction processing systems (TPS) and the role they play in a business. 2. Describe the characteristics of management information systems (MIS), de

> Henry’s Hardware is a small family business in Sacramento, California. The owners must use every square foot of store space as profitably as possible. They have never kept detailed inventory or sales records. As soon as a shipment of goods arrives, the i

> During a typical trip to the doctor, you’ll often see shelves full of folders and papers devoted to the storage of medical records. The majority of medical records are currently paper-based, making these records very difficult to access and share. It has

> Identify the steps that are performed in the process of selecting and checking a book out from your college library and the information that flows among these activities. Diagram the process. Are there any ways this process could be improved to improve t

> If you haven't heard of Valero don't worry. It's largely unknown to the public, although investors recognize it as one of the largest oil refiners in the United States. Valero Energy is a top-10 Fortune company headquartered in San Antonio, Texas, with 2

> It’s been a rough decade for the airline industry. Terrorism scares, rising fuel prices, and overall economic malaise have combined to damage airline companies’ bottom lines. In 2007, nearly every major airline began charging baggage fees to generate rev

> Why are information systems so essential for running and managing a business today? List and describe six reasons why information systems are so important for business today.

> Dollar General Corporation operates deep-discount stores offering housewares, cleaning supplies, clothing, health and beauty aids, and packaged food, with most items selling for $1. Its business model calls for keeping costs as low as possible. The compa

> If you were setting up the Web site for Disney World visitors, what people, organization, and technology issues might you encounter?

> United Parcel Service (UPS) started out in 1907 in a closet-sized basement office. Jim Casey and Claude Ryan—two teenagers from Seattle with two bicycles and one phone—promised the “best service and lowest rates.” UPS has used this formula successfully f

> Can you run your company from the palm of your hand? Perhaps not entirely, but there are many functions today that can be performed using an iPhone, iPad, BlackBerry, or other mobile handheld device. The BlackBerry has been the favorite mobile handheld f

> What major features of a business are important for understanding the role of information systems? 1. Define a business and describe the major business functions. 2. Define business processes and describe the role they play in organizations. 3. Identify

> Snyders of Hanover, which sells about 80 million bags of pretzels, snack chips, and organic snack items each year, had its financial department use spreadsheets and manual processes for much of its data gathering and reporting. Hanover’s financial analys

> United Parcel Service (UPS) started out in 1907 in a closet-sized basement office. Jim Casey and Claude Ryan—two teenagers from Seattle with two bicycles and one phone—promised the “best service and lowest rates.” UPS has used this formula successfully f

> For the Tax Court, the District Court, and the Court of Federal Claims, indicates the following. a. Number of regular judges per court. b. Availability of a jury trial. c. Whether the deficiency must be paid before the trial.

> A taxpayer lives in Michigan. In a controversy with the IRS, the taxpayer loses at the trial court level. Describe the appeal procedure for each of the following trial courts. a. Small Cases Division of the Tax Court. b. Tax Court. c. District Court. d.

> Eddy Falls is considering litigating a tax deficiency of approximately $229,030 in the court system. He asks you to provide him with a short description of his litigation alternatives, indicating the advantages and disadvantages of each. Prepare your res

> An accountant friend of yours tells you that he “almost never” does any tax research because he believes that “research usually reveals that some tax planning idea has already been thought up and shot down.” Besides, he points out, most tax returns are n

> Underwood, the CFO of Tech Co, Inc., has used ASC 740-30 (APB 23) to avoid reporting any U.S. deferred tax expense on $50 million of the earnings of Tech Co’s foreign subsidiaries. All of these subsidiaries operate in countries with lower tax rates than

> Jill is the CFO of PorTech, Inc. PorTech’s tax advisers have recommended two tax planning ideas that will each provide $5 million of current-year cash tax savings. One idea is based on a timing difference and is expected to reverse in full 10 years in th

> You saw on the online Business News Channel that Young Co has “released one-third of its valuation allowances because of an upbeat forecast for sales of its tablet computers over the next 30 months.” What effect does such a release likely have on Young C

> Using the facts of Problem 15, determine the 2015 end-of-year balance in Mini’s deferred tax asset and deferred tax liability balance sheet accounts. Problem 15: Mini, in Problem 13, reports $800,000 of pretax book net income in 2015. Mini did not deduc

> List an advantage and a disadvantage of using the U.S. Court of Federal Claims as the trial court for Federal tax litigation.

> Mini, in Problem 13, reports $800,000 of pretax book net income in 2015. Mini did not deduct any bad debt expense for book purposes but did deduct $15,000 in bad debt expense for tax purposes. Mini records no other temporary or permanent differences. Ass

> Using the facts of Problem 11, determine the 2015 end-of-year balance in Prance’s deferred tax asset and deferred tax liability balance sheet accounts. Problem 11: Prance, in Problem 4, reports $600,000 of pretax book net income in 2015. Prance’s book d

> Prance, in Problem 4, reports $600,000 of pretax book net income in 2015. Prance’s book depreciation exceeds tax depreciation in this year by $20,000. Prance reports no other temporary or permanent book-tax differences. Assuming that the pertinent U.S. t

> In no more than three PowerPoint slides, list several commonly encountered temporary and permanent book-tax differences. The slides will be used in your presentation next week to your school’s Future CPAs Club.

> Marcellus Jackson, the CFO of Mac, Inc., notices that the tax liability reported on Mac’s tax return is less than the tax expense reported on Mac’s financial statements. Provide a letter to Jackson outlining why these two tax expense numbers differ. Mac’

> Go to www.legalbitstream.com, and find the case in which Mark Spitz, the Olympic gold medalist, is the petitioner. Answer the following questions. a. What tax years are at issue in the case? b. In what year was the case decided? c. What tax issues were i

> Evaluate the following statement: For most business entities, book income differs from taxable income because “income” has different meanings for the users of the data in the income computation.

> Prance, Inc., earns pretax book net income of $800,000 in 2014. Prance acquires a depreciable asset in 2014, and first-year tax depreciation exceeds book depreciation by $80,000. Prance reported no other temporary or permanent book-tax differences. The p

> Ion Corporation reports an income tax expense/payable for book purposes of $200,000 and $250,000 for tax purposes. According to Ion’s management and financial auditors, Ion will only be able to use $30,000 of any deferred tax asset, with the balance expi

> Interpret each of the following citations. a. Temp. Reg. § 1.956–2T. b. Rev. Rul. 2012–15, 2012–23 I.R.B. 975. c. Ltr. Rul. 200204051.

> Ovate, Inc., earns $140,000 in book income before tax and is subject to a 35% marginal Federal income tax rate. Ovate records a single temporary difference: Warranty expenses deducted for book purposes are $8,000, of which only $2,000 are deductible for

> Develop an outline from which you will deliver a 10-minute talk to the local Chamber of Commerce, with the title “Regulation of the Tax Profession in the 21st Century.” Use no more than four PowerPoint slides for your talk, and discuss what the business

> Using the title “The Federal Taxing System Operates Outside the U.S. Constitution,” write a two-page paper to submit in your Government Policy course. Do not address “tax protester” issues (e.g., that the income tax is unconstitutional or that one’s taxe

> A friend of yours, who is a philosophy major, has overheard the conversation described in Problem 28 and declares that all tax research is “immoral.” She says that tax research enables people with substantial assets to shift the burden of financing publi

> Comment on these statements. a. The tax law is created and administered in the same way as other Federal provisions. b. Most taxpayers find it too expensive and time-consuming to sue the government in a tax dispute.

> What precedents must each of these courts follow? a. U.S. Tax Court. b. U.S. Court of Federal Claims. c. U.S. District Court.

> This year, Frank lived with and supported Daisy, an unrelated 20-year-old woman to whom he was not married. Frank lives in a state that has a statute that makes cohabitation a misdemeanor for a man and a woman who are not married to each other. May Frank

> Locate the following items, and e-mail to your professor a brief summary of the results. a. Charles Y. Choi, T.C. Memo. 2002–183. b. Ltr.Rul. 200231003. c. Action on Decision, 2000–004, May 10, 2000.

> Find one instance of each of the following using a nonsubscription site on the Web or an online library at your school. In an e-mail to your professor, give a full citation for the document and describe how you found it. a. Letter Ruling. b. Action on De

> Find three blogs related to tax practice. On one PowerPoint slide, list the URLs for each blog and the general topical areas addressed at each. Send your slide to the others in your course.

> Rank the following items from the lowest to the highest authority in the Federal tax law system. a. Interpretive Regulation. b. Legislative Regulation. c. Letter ruling. d. Revenue Ruling. e. Internal Revenue Code. f. Proposed Regulation.

> Go to www.legalbitstream.com, and find the case in which Mark Spitz, the Olympic gold medalist, is the petitioner. Answer the following questions. a. What tax years are at issue in the case? b. In what year was the case decided? c. What tax issues were i

> This year, Frank lived with and supported Daisy, an unrelated 20-year-old woman to whom he was not married. Frank lives in a state that has a statute that makes cohabitation a misdemeanor for a man and a woman who are not married to each other. May Frank

> Find Kathryn Bernal, 120 T.C. 102 (2003), and answer the following questions. a. What was the docket number? b. When was the dispute filed? c. Who is the respondent? d. Who was the attorney for the taxpayers? e. Who was the judge who wrote the opinion? f

> Can a Tax Court Small Cases decision be treated as a precedent by other taxpayers? Explain. Partial list of research aids:§ 7463(b). Maria Antionette Walton Mitchell, T.C. Summary Opinion 2004–160.

> Locate the following Tax Court case: Thomas J. Green, Jr., 59 T.C. 456 (1972). Briefly describe the issue in the case, and explain what the Tax Court said about using IRS publications to support a research conclusion.

> Determine the missing data in these court decisions and rulings. a. Higgins v. Comm., 312 U.S.______ (1941). b. Talen v. U.S., 355 F.Supp.2d 22 (D.Ct. D.C., ______). c. Rev.Rul. 2008–18, 2008–13 I.R.B.______. d. Pahl v. Comm., 150 F.3d 1124 (CA–9, ______

> Describe the material that is found in Subtitle E of the Code. Would you expect these provisions not to be addressed anywhere else in the Code? Explain.

> Find Kathryn Bernal, 120 T.C. 102 (2003), and answer the following questions. a. What was the docket number? b. When was the dispute filed? c. Who is the respondent? d. Who was the attorney for the taxpayers? e. Who was the judge who wrote the opinion? f

> Locate the following Regulations, and give a brief topical description of each. Summarize your comments in an e-mail to your instructor. a. Reg. § 1.170A–4A(b)(2)(ii)(C). b. Reg. § 1.672(b)–1. c. Reg. § 20.2031–7(f).

> Locate the following Code citations, and give a brief topical description of each. a. § 708(a). b. § 1371(a). c. § 2503(a).

> Distinguish between the following. a. Treasury Regulations and Revenue Rulings. b. Revenue Rulings and Revenue Procedures. c. Revenue Rulings and letter rulings. d. Letter rulings and determination letters.

> Is there an automatic right to appeal to the U.S. Supreme Court? If so, what is the process?

> In the citation Schuster’s Express, Inc., 66 T.C. 588 (1976), aff’d 562 F.2d 39 (CA–2, 1977), nonacq., to what do the 66, 39, and nonacq. refer?

> To locate an IRS Revenue Procedure that was issued during the past week, which source would you consult? a. Federal Register. b. Internal Revenue Bulletin. c. Internal Revenue Code. d. Some other source. Identify it.

> In which Subchapter of the Internal Revenue Code would one find information about corporate distributions? a. Subchapter S. b. Subchapter C. c. Subchapter P. d. Subchapter K. e. Subchapter M.

> Using the legend provided, classify each of the following tax sources. a. Sixteenth Amendment to the U.S. Constitution. b. Tax treaty between the United States and India. c. Revenue Procedure. d. Chief Counsel Advice (issued 2009). e. U.S. District Court

> Using the legend provided, classify each of the following citations as to the type of court. a. Rev.Rul. 2009–34, 2009–42 I.R.B. 502. b. Joseph R. Bolker, 81 T.C. 782 (1983). c. Magneson, 753 F.2d 1490 (CAâ€

> Using the legend provided, classify each of the following statements (more than one answer per statement may be appropriate). a. Decides only Federal tax matters. b. Decisions are reported in the F.3d Series. c. Decisions are reported in the USTCs. d. De

> Which of the following items may be found in the Internal Revenue Bulletin? a. Action on Decision. b. Small Cases Division of the Tax Court decision. c. Letter ruling. d. Revenue Procedure. e. Final Regulation. f. Court of Appeals decision. g. Acquiescen

> Can a Tax Court Small Cases decision be treated as a precedent by other taxpayers? Explain. Partial list of research aids:§ 7463(b). Maria Antionette Walton Mitchell, T.C. Summary Opinion 2004–160.

> What is meant by the term petitioner?

> Locate the following Code provisions, and give a brief description of each in an e-mail to your instructor. a. § 61(a)(13). b. § 643(a)(2). c. § 2503(g)(2)(A).

> Tom, an individual taxpayer, has been audited by the IRS and, as a result, has been assessed a substantial deficiency (which has not yet been paid) in additional income taxes. In preparing his defense, Tom advances the following possibilities. a. Althoug

> For her tax class, Yvonne is preparing a research paper discussing the tax aspects of child support payments. Explain to Yvonne how she can research the provisions on this topic.

> Answer the following questions based upon this citation: United Draperies, Inc.v. Comm., 340 F.2d 936 (CA–7, 1964), aff’g 41 T.C. 457 (1963), cert. denied 382U.S. 813 (1965). a. In which court did this decision first appear? b. Did the appellate court up

> Interpret each of the following citations. a. 14 T.C. 74 (1950). b. 592 F.2d 1251 (CA–5, 1979). c. 95–1 USTC { 50,104 (CA–6, 1995). d. 75 AFTR 2d 95–110 (CA–6, 1995). e. 223 F.Supp. 663 (W.D. Tex., 1963).

> Referring to the citation only, determine which tax law source issued these documents. a. 716 F.2d 693 (CA–9, 1983). b. 92 T.C 400 (1998). c. 70 U.S. 224 (1935). d. 3 B.T.A. 1042 (1926). e. T.C.Memo. 1957–169. f. 50 AFTR 2d 92–6000 (Cl.Ct., 1992). g. Ltr

> Explain the following abbreviations. a. CA-2, b. Fed.Cl. c. affd. d. reu'd. Cert. den ied. k. F3d. 1. FSupp. m. USSC. n. S.a. o. D.A. f. 8. acq. h. В.ТА. i USTC. j. AFTR e. rem 'd.

> What is the difference between a Regular decision, a Memorandum decision, and a Summary Opinion of the Tax Court?

> In assessing the validity of a prior court decision, discuss the significance of the following on the taxpayer’s issue. a. The decision was rendered by the U.S. District Court of Wyoming. Taxpayer lives in Wyoming. b. The decision was rendered by the Cou

> A taxpayer living in the following states would appeal a decision of the U.S District Court to which Court of Appeals? a. Wyoming. b. Nebraska. c. Idaho. d. Louisiana. e. Illinois.

> Locate the following Tax Court case: Thomas J. Green, Jr., 59 T.C. 456 (1972). Briefly describe the issue in the case, and explain what the Tax Court said about using IRS publications to support a research conclusion.

> Go to the U.S. Tax Court website. a. What different types of cases can be found on the site? b. What is a Summary Opinion? Find one. c. What is a Memorandum decision? Find one. d. Find the court’s Rules of Practice and Procedures. e. Is the site user-fri

> An accountant friend of yours tells you that he “almost never” does any tax research because he believes that “research usually reveals that some tax planning idea has already been thought up and shot down.” Besides, he points out, most tax returns are n

> Determine the missing data in these court decisions and rulings. a. Higgins v. Comm., 312 U.S.______ (1941). b. Talen v. U.S., 355 F.Supp.2d 22 (D.Ct. D.C., ______). c. Rev.Rul. 2008–18, 2008–13 I.R.B.______. d. Pahl v. Comm., 150 F.3d 1124 (CA–9, ______

> Butch Bishop operates a small international firm named Tile, Inc. A new treaty between the United States and Spain conflicts with a Section of the Internal Revenue Code. Butch asks you for advice. If he follows the treaty position, does he need to disclo

> What precedents must each of these courts follow? a. U.S. Tax Court. b. U.S. Court of Federal Claims. c. U.S. District Court.

> Using the title “The Federal Taxing System Operates Outside the U.S. Constitution,” write a two-page paper to submit in your Government Policy course. Do not address “tax protester” issues (e.g., that the income tax is unconstitutional or that one’s taxe

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