A friend notices that you are reading the Internal Revenue Code of 1986. Your friend inquires
why you are consulting a 1986 publication, especially when tax laws change so frequently. What
is your response?
A. It is updated for every statutory change to Title 26 subsequent to 1986. Therefore it
...
a friend notices that you are reading the internal revenue code of 1986 your friend inquires why you are consulting a 1986 publication
especially when tax laws change so frequently what is your res
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ACC-331 Pearson Midterm Exam
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A friend notices that you are reading the Internal Revenue Code of 1986. Your friend inquires
why you are consulting a 1986 publication, especially when tax laws change so frequently. What
is your response?
A. It is updated for every statutory change to Title 26 subsequent to 1986. Therefore it
includes the post-1986 tax law changes enacted by Congress and today reflects the current
state of the law.
B. It is the last time the code was published, therefore it is easier to read Title 26 of 1986 first,
and then research updated tax law for anything newer in the committee reports.
C. It is always the first place you should start any research project.
D. The Internal Revenue Code of 1986 is the first time the statutory law was printed in one book,
or as Title 26, and is therefore the only way to find the codification of laws.
Requirement
Provide the proper citations (including both primary and secondary citations where applicable)
for the authorities listed below. (For secondary citations, reference both the AFTR and USTC.)
(Ignore lack of italics in selections.)
a.
Rev. Rul. 99-7
b.
Frank H. Sullivan, a Board of Tax Appeals decision
c.
Tate & Lyle, Inc., a 1994 Tax Court decision
d.
Ralph L. Rogers v. U.S., a U.S. district court decision
e.
Norman Rodman v. CIR, a Second Circuit Court decision
a. Rev. Rul. 99-7
Citation:
Rev. Rul. 99-7, 1999-1 C.B. 361.
b. Frank H. Sullivan, a Board of Tax Appeals decision
Citation:
Frank H. Sullivan, 1 B.T.A. 93 (1924).
c. Tate & Lyle, Inc., a 1994 Tax Court decision
Citation:
Tate and Lyle, Inc., 103 T.C. 656 (1994).
d. Ralph L. Rogers v. U.S., a U.S. district court decision
Citation:
Ralph L. Rogers v. U.S., 539 F. Supp. 104, 49 AFTR 2d 82-1160, 82-1 USTC ¶ 9246 (DC
OH, 1982).
e. Norman Rodman v. CIR, a Second Circuit Court decision
Citation:
Norman Rodman v. CIR, 542 F.2d 845, 38 AFTR 2d 76-5840, 76-2 USTC ¶ 9710 (2nd Cir.,
1976).
,List four methods of searching the CHECKPOINT and INTELLICONNECT databases.
A. Citation, date, keyword, or author
B. Keyword, index, citation, or content
C. Groupings, date, author, or content
D. Author, groupings, citation, or content
Rev. Rul. 2001-29 interprets Section(s) 355 and 856.
What two functions does a citator serve?
A. Citators (1) assist in internet-based tax research by grouping words together and (2) list
common words together during a search so you can refine your results after the initial query.
B. Citators (1) trace the history of the case in question and (2) assist in internet-based tax
research by grouping words together.
C. Citators (1) trace the history of the case in question and (2) list other authorities that
have cited such cases.
D. Citators (1) list common words together during a search so you can refine your results after
the initial query and (2) list other authorities that have cited such cases.
Describe two ways that the information available from the CHECKPOINT citator differs from
that available from the INTELLICONNECT citator.
A. CHECKPOINT indicates how the case in question was cited, when INTELLICONNECT only
lists the case for the researcher to read themselves.
B. CHECKPOINT lists all citing cases, however INTELLICONNECT which just lists those that
the editors believe will serve as precedent.
C. CHECKPOINT allows the researcher to enter case names or case citations. Unlike
INTELLICONNECT which only allows a researcher to enter case citations.
D. Both A and B.
Look up Bush Brothers & Co., 73 T.C. 424 (1979) and answer the questions below.
Requirements
a. Was the case reviewed by the court? If so, was the decision unanimous? Explain.
b. Was the decision entered under Rule 155?
c. Consult a citator. Was the case reviewed by an appellate court? If so, which one?
Requirement a. Was the case reviewed by the court? If so, was the decision unanimous? Explain.
A. Yes. The case was reviewed by the court. The decision was not unanimous. Judge Quealy
dissented. Judge Tannenwald issued a concurring opinion with which five judges agreed.
Judge Chabot issued a dissenting opinion with which three judges agreed, and Judge Nims
issued a dissenting opinion with which three judges agreed.
B. Yes. The case was reviewed by the court. The decision was unanimous. Judge Chabot issued a
dissenting opinion with which all judges agreed.
C. No. The case was not reviewed by the court.
D. Yes. The case was reviewed by the court. The decision was unanimous. Judge Tannenwald
issued a concurring opinion with which all judges agreed.
, Requirement b. Was the decision entered under Rule 155?
No. The decision was not entered under Rule 155.
Requirement c. Consult a citator. Was the case reviewed by an appellate court? If so, which one?
Yes. The case was reviewed by the Sixth Circuit Court of Appeals in 1982.
Debate the following proposition: All corporate formation transactions should be taxable events.
Select the pro's for this debate. (Select all that apply.)
A. Making a corporate formation a taxable event decreases tax revenues.
B. This change eliminates the need for taxpayers to artificially structure transaction to
avoid Sec. 351 to recognize gains and/or losses.
C. Simplification is achieved by eliminating one of the two options - whether a transaction
is taxable or not. This change will make administration of the tax laws easier.
D. A corporate formation is a deemed stock purchase; therefore, parties to this stock purchase do
not have to recognize gains or losses until they leave the corporation.
Select the con's for this debate. (Select all that apply.)
A. With taxation, businesses would be encouraged to incorporate because of the tax benefits that
boost economic growth in the U.S.
B. This change would hurt start-up corporations by reducing their capital through the
income tax paid by transferors on an asset transfer.
C. Taxpayers are required to recognize losses under the current system, thereby decreasing
revenues to the government.
D. With taxation, corporations will have to raise more capital because transferors of
noncash property will have reduced capital to invest and because money must be diverted
to pay taxes.
In 2013, Mick, George, and Lesley form Zeus Corporation. Mick contributes land (a capital
asset) having a $62,500 FMV in exchange for 100 shares of Zeus stock. He purchased the land
in 2011 for $140,000. George contributes machinery (Sec. 1231 property purchased in 2010)
having a $130,000 adjusted basis and a $37,500 FMV in exchange for 90 shares of Zeus stock.
Lesley contributes services worth $25,000 in exchange for 10 shares of Zeus stock.
Read the requirements.
Requirement a. What is the amount of Mick's recognized gain or loss?
Mick realizes a $77,500 loss and recognizes no gain or loss.
Requirement b. What is Mick's basis in his Zeus shares? When does his holding period begin?
Mick's basis in the Zeus shares is $140,000 and his holding period for the stock begins in
2011.
Requirement c. What is the amount of George's recognized gain or loss?
George realizes a $92,500 loss and recognizes no gain or loss.
Requirement d. What is George's basis in his Zeus shares? When does his holding period begin?
George's basis in the Zeus shares is $130,000 and his holding period for the stock begins in 2010.
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