What are some advantages of CATR?
> Fernando has been an attorney in the legal department of Mega Manufacturing, Inc., for the past 15 years. As part of Mega’s restructuring plan, he will lose his job as an employee of Mega, but he will continue contracting with Mega to work on specific e
> George and June are active volunteers in their local church. George serves as an usher one Sunday morning a month. June sings in the church choir every Sunday morning and attends choir practice each Wednesday evening. Based on the distance from their
> Marnie buys 500 shares of qualified small business stock in H.R. Pizza, Inc., on September 10, 2008 for $20,000. She sells the 500 shares for $120,000 on October 2, 2017. Marnie's other capital asset transactions consist of a $7,000 short-term capital
> What is the purpose of the capital gain-and-loss netting procedure?
> Seaweed Salvagers is a corporation engaged in producing foodstuffs from seaweed. Seaweed's primary salvaging plant is located in California. Because the salvaging technology hasn't changed through the years, Seaweed's primary salvaging equipment was pu
> Jefferson is a grade school teacher whose annual income from teaching is $30,000. He has always enjoyed bowling and his local pro urged him to turn professional. He subsequently begins working for the pro as an unpaid assistant and enters an apprentice
> Mason owns Brickman, Inc., which specializes in laying brick patios, terraces, and walkways. Mason bids on a contract with State University to build several large terraces as well as the walkways adjoining the terraces. Although he is the low bidder, M
> Harvey is employed by the U.S. Customs Service. Early in the year he accepts a position in the London office. In addition to a raise in his pay grade, the terms of the London assignment let Harvey collect a monthly living quarters allowance (LQA) for r
> Francine is a self-employed marketing consultant based in Fort Worth, Texas. During the year, she travels to various cities in the United States to meet prospective clients and make presentations at seminars. Francine can substantially reduce her airfa
> Larry is a professional gambler, specializing in dog racing. He spends 50 to 60 hours per week studying racing forms and placing bets at the track. During the current year Larry has winnings of $240,000 on $380,000 of bets placed. He has no other busi
> Jon purchases a farm for $2,200,000. The previous owners planted parallel rows of bushes and trees on the land when they acquired it to block the wind from the part of the farm that was planted with crops. The trees and bushes have never produced salabl
> Rosemary attends classes provided by her church. She makes payments to the church, which are required to attend classes. She plans to deduct the payments as charitable contributions to her church. Can Rosemary deduct the payments as charitable contrib
> Warren is chief executive of a major corporation and is very concerned about his premature balding. He contacts a hair transplant specialist and wants to have surgery performed this year. Write a memo advising Warren whether the hair transplant surgery
> Grace, the minister of the local United Methodist Church, has some tax questions regarding her employment status. This is her first year as a United Methodist minister after having served as a Baptist preacher for twenty years. She wonders if the conve
> Thuy buys a rental house in 2010 for $75,000. In 2017, she sells it for $86,000. Thuy properly deducted $22,000 in depreciation on the house before its sale. a. What is the amount and character of the gain on the sale? b. Thuy also sells the following
> The Kona Rural Electric Coop (KREC) is an accrual basis public utility. All new customers are required to pay a deposit equal to 3 times the customer's estimated monthly bill or $100, whichever is greater. The purpose of the deposit is to ensure that ti
> Mr. and Mrs. Lucky have been married for 25 years. Last year, they won $200,000 at a casino. They knew that this would put them in the highest tax bracket for the year. To avoid this, they went to Mexico on December 28 and obtained a divorce. They co
> Lydia and Andre are divorcing this year. Because they are hotly contesting the terms of the settlement, they will not file a joint return for the current year. Lydia receives a Form 1099-INT from Andre's accountant and a letter stating that Lydia shoul
> Ernie's Farm and Garden Implement Store sells, repairs, and services farm and garden equipment. In 2016, the state attorney general began to investigate customers' complaints that Ernie's was adding a delivery and handling fee to each product---fees tha
> Tomiko owns the copyright to several classic Motown songs. In 2015, he became aware that Tinseltown Records was selling several of his songs without his permission. He sues Tinseltown seeking $1,000,000 in damages. In 2017, the court awards Tomiko $50
> Al is in the state penitentiary after being convicted of a series of crimes. He still corresponds with his girlfriend to ask for money and this year she has sent him a total of $1,200. Al’s only other income is the $1,000 he has been paid for making li
> Name the other types of pronouncements issued by the IRS, and briefly describe their content.
> What impact would an IRS announcement of nonacquiescence to a court decision have on a taxpayer in a similar situation?
> What does it mean when the IRS issues an acquiescence or nonacquiescence?
> How are a revenue ruling and a Treasury regulation different? a revenue ruling and a private letter ruling?
> Assume that the building in problem 68 is an apartment building held for investment. In addition to the sale of the building, Anton has the following capital gains and losses during 2017: Short-term capital loss………………………………………………….$ 4,000 Collectibles
> What are revenue rulings? revenue procedures?
> Differentiate a proposed regulation and a temporary regulation.
> Differentiate an interpretive regulation and a legislative regulation.
> What is a Treasury regulation? Is it binding on the courts?
> How are the Joint Conference Committee and the Joint Committee on Taxation different?
> What three reports are issued as part of the legislative process?
> Briefly describe the process by which a new tax law is passed.
> Give examples of how the Code is sometimes used to achieve economic and social objectives.
> What are some things to look out for when reading the Code?
> Name the types of secondary authorities.
> Anton purchases a building on May 4, 2000, at a cost of $270,000. The land is properly allocated $30,000 of the cost. Anton sells the building on October 18, 2017, for $270,000. What is the character of Anton's gain or loss on the sale if he uses the
> Briefly describe the three categories of primary authorities and the types of authorities within each category.
> Differentiate primary tax law authorities and secondary tax law authorities.
> Briefly describe the steps involved in tax research.
> What is the distinction between tax compliance and tax planning?
> Use any print or CATR service to find the following information about the Protecting Americans from Tax Hike Act of 2015: a. The public law number and enactment date b. A reference to the full text of the act c. A secondary authority that discusses the a
> Use any print or CATR service or the Internet to find the name of a 1995 Supreme Court decision involving the taxability of a settlement received as compensation for age discrimination. Find the name of the case, a standard legal citation, and the date t
> Use any print or CATR service or the Internet to find a Code section(s) on the following general tax concepts topics. For each item, indicate the Code section number(s) and the full title of the relevant Code section(s). a. Income tax rates for individu
> Use any print or CATR service or the Internet to find a Code section(s) on the following property and cost recovery topics. For each item, indicate the Code section number(s) and full title of the relevant Code section(s). a. Basis of player contracts on
> Use any print or CATR service or the Internet to find a Code section(s) on the following loss topics. For each item, indicate the Code section number(s) and full title of the relevant Code section(s). a. Bad debts b. Net operating loss deduction c. Passi
> Use any print or CATR service or the Internet to find a Code section(s) on the following deduction topics. For each item, indicate the Code section number(s) and full title of the relevant Code section(s). a. Charitable contributions b. Dividends-receive
> Manuel is negotiating the sale of two of his rental properties. He has an offer of $500,000 for each condo. Manuel bought one condo in 1986 for $400,000 and has deducted depreciation of $185,000 using ACRS (accelerated depreciation). Straight-line dep
> Use any print or CATR service or the Internet to find a Code section(s) on the following income topics. For each item, indicate the Code section number(s) and full title of the relevant Code section(s). a. Discharge of indebtedness b. Exclusion for emplo
> Assume that you have found an excellent article in Tax Notes that provides a favorable interpretation of Sec. 469. Can you rely on that article as authority for your position? In general, what role do tax periodicals and newsletters play in tax research
> When can a researcher rely on an editorial opinion expressed in the tax services?
> Describe the two major categories of tax services.
> Provide the correct citations for the following: a. The fifteenth revenue procedure issued in 1993 and found on page 12 of the third Internal Revenue Bulletin issued in 1993. b. Subsection (a) of the first temporary income tax regulation interpreting Sec
> Interpret the following citations: a. Senate Finance Committee, S. Rep. No. 2, 97th Cong., 2d Sess. (April 15, 1982). b. LTR 8101067. c. Rev. Proc. 78-172, 1978-2 C.B. 22. d. Lacy v. Comm., 344 F.2d 123, 89-1 USTC ¶1221, 43 A.F.T.R. 89-2233 (9th Cir., 19
> Assume that the Supreme Court interprets a certain Code section in a manner that members of Congress believe is contrary to what they meant when they enacted that part of the Code. What (if anything) can Congress do?
> Do district courts have to follow the decisions of all circuit courts?
> What is meant by the Golsen rule?
> Nadia sells land for $4,000 and the buyer assumes her $13,000 mortgage. She pays $1,000 in real estate commissions on the sale. Identify the tax issue(s) posed by the facts presented. Determine the possible tax consequences of each issue that you ident
> What are the three trial courts? Which is most important?
> Name the subdivisions of the Internal Revenue Code.
> The Internal Revenue Code is just one part of the U.S. Code. Explain.
> On what grounds have tax protesters challenged the income tax?
> Use any print or CATR service or the Internet to find the Revenue Ruling or Revenue Procedure that provides instructions on requesting a letter ruling. Indicate the number of the Revenue Ruling or Revenue Procedure, and the IRS reference.
> What is meant by the history of a cited case?
> Differentiate a cited case and a citing case.
> Why do some court decisions have two or three different citations?
> What does it mean when the Supreme Court issues a writ of certiorari?
> How many chapters are within Subtitle A?
> Bernadero Corporation sells a construction crane with an adjusted basis of $32,000 for $37,000. The corporation paid $50,000 for the crane. Identify the tax issue(s) posed by the facts presented. Determine the possible tax consequences of each issue th
> What would be the general nature of Sec. 612? Sec. 6601?
> Fred, age 50, plans to retire when he reaches age 65. He is considering investing in either an IRA or a Roth IRA. He plans to contribute $6,500 per year until he retires. He expects his marginal tax rate to be 28% until he retires, when he expects the
> William, Daniel, and Thomas are brothers who have decided to form an engineering firm. Although Thomas has an MBA degree and will function primarily as the firm’s financial expert, he has no formal tax knowledge. William and Daniel are bringing clients
> Assume the same facts as in problem 87. In the next year, TAG distributes $5,000 to Logo. What are the tax effects of the distribution? Data from Problem 87: Logo Corporation, a domestic corporation, owns 100% of TAG, a foreign corporation. TAG is Log
> Assume that in problem 77, Stan sells the machinery in 2023 for $28,500. Determine the effect of the sale on Stan's regular taxable income and his alternative minimum taxable income in 2023. Data from Problem 77: Stan purchases machinery costing $100,0
> Stan purchases machinery costing $100,000 for use in his business in 2017. The machinery is 7-year MACRS property and has an ADS life of 12 years. Prepare a depreciation schedule using the regular MACRS method and ADS depreciation assuming that Stan do
> Determine the total amount of tax due and the amount of the alternative minimum tax in each of the following situations: a. Wilbur Corporation's regular tax liability is $180,000, and its tentative alternative minimum tax is $150,000. b. Gene's regular t
> Willtem Corporation has total general business credits of $25,000. It has a net regular tax liability of $17,000 and its tentative alternative minimum tax is $13,000. What can Willtem deduct as its general business credit?
> Hurst Corporation wants to provide child care for its employees. Because Hurst does not have a suitable facility on its own premises, it rents a building for the center. The rent for the year totals $61,000. In addition, Hurst hires a qualified direct
> Return to the facts of problem 72. Assume that Lavinia sells the building in April 2020. a. How much of the older buildings tax credit must Lavinia recapture? b. Assuming the building qualified for both credits, how much of the historic structures credi
> Jammer, Inc., sells a building for $180,000. The company paid $135,000 for the building four years earlier and had taken $12,000 in depreciation on it up to the date of the sale. Identify the tax issue(s) posed by the facts presented. Determine the pos
> Lavinia owns an advertising agency. In February 2017, Lavinia purchases for $32,000 a building that was originally placed in service in 1922. Lavinia spends $65,000 rehabilitating the building for use as her advertising agency office. The rehabilitation
> Clinton Corporation spent $800,000 on qualified research activities during the current year. Clinton's fixed base percentage is 10%, and its annual average gross receipts for the four preceding years is $2,000,000. a. What is Clinton's allowable increme
> Sonya owns 60% and her sister Karen owns 40% of the Tanglewood Group. They inherited their ownership from their mother who died in 2016. Sonya is the president and CFO of the corporation and receives a salary of $140,000, which is reasonable given her
> On July 1, 2017, Howard is granted the right to acquire 500 shares of the Matoney Corporation for $15 per share. The option qualifies under the company’s incentive stock option plan. The current fair market value of the stock is $12. On August 18, 20
> Return to the facts of problem 67. Assume that Louise sells the stock on October 31, 2018 for $35 per share. Determine the tax consequences for Louise and Somerton on the date of sale. Data from Problem 66 and 67 On May 10, 2017, Somerton Inc., grants
> Return to the facts of problem 66. If the stock is subject to substantial restrictions, what are the tax consequences for both Louise and Somerton on the date Louise is granted the stock option and the date she exercises the stock assuming she does not
> On May 10, 2017, Somerton Inc., grants Louise a nonqualified stock option to acquire 700 shares of the company’s stock for $11 per share. The fair market value of the stock on the date of grant is $13. The option does not have a readily ascertainable f
> Return to the facts of problem 64. On November 30, 2018, when the fair market value of the stock is $30 he sells the stock. Determine the tax consequences to both Albert and the Beaconsfield Corporation in each situation presented in problem 64. Data
> On September 1, 2017, Beaconsfield Corporation grants Albert a nonqualified stock option to acquire 500 shares of the company’s stock for $8 per share. The fair market value of the stock on the date of grant is $14. Determine the tax consequences to bo
> Juan and Angel, ages 56 and 54, respectively, decide to establish Roth IRAs. Juan and Angel are married, and both are covered by pension plans where they work. Their adjusted gross income is $125,000. They want to make the maximum contribution to the
> Bostian Company reports a net Section 1231 gain of $31,000 during the current year. Identify the tax issue(s) posed by the facts presented. Determine the possible tax consequences of each issue that you identify.
> Glenna is retired from the Cherry Hills Corporation. When she retired at 68, she decided to take her pension as a lump-sum distribution and roll over the proceeds tax free into her IRA. On January 1, 2015, she began to receive the required $22,000 dist
> During the current year, Kyung purchases a boat for $70,000. Because she has only $7,000 of the necessary $14,000 down payment, Kyung makes a $7,000 withdrawal from her IRA account. Immediately before the withdrawal, the balance in her account consists
> Ross is single and maintains an IRA. During a trip to Las Vegas in 2017, he wins $14,000 at the roulette wheel. He decides to put half his earnings in his IRA account and spend the other half on a trip to Europe. At the end of 2017, the total assets i
> Hector is a single taxpayer with adjusted gross income of $123,000. What is the maximum contribution that he can make to a Roth IRA for the current year?
> Suresh is sales representative for Swinley Manufacturing. The corporation maintains a defined contribution profit sharing plan on behalf of its employees. The company contributes 15% of each employee’s salary. Suresh’s salary for the year is $200,000.
> Felicia is a single taxpayer who retired from her job as a sales executive with Waynesville Associates, LLC. During 2016, she turns 70 ½ and decides to begin withdrawing the $320,000 in assets (balance as of December 31, 2015) in her pension account. H
> Ghon is a married taxpayer who retired from his job at Smithfield Printing in 2016. During 2017, he turns 70 1/2 and begins withdrawing the $215,000 (balance December 31, 2016) in assets in his pension account. Smithfield maintains a noncontributory pe
> In October 2016, the Clark Corporation decides to establish a SIMPLE-401(k) retirement plan for its employees. Clark meets all requirements for establishing a SIMPLE. The company has notified its employees that in 2017, it will fund the SIMPLE-401(k) by
> Lenore, a single taxpayer with adjusted gross income of $66,000, is covered by her employer's pension plan. She makes a $5,500 contribution to her IRA during the current year. a. How much of the contribution can Lenore deduct? b. Assume the same facts
