,Pearson's Federal Taxation 2019: Comprehensive, 32e (Rupert/Anderson)
Chapter C1: Tax Research
LO1: Overview of Tax Research
1) Tax planning is not an integral part of open-fact situations.
Answer: FALSE
Page Ref.: C:1-2
Objective: 1
2) When a taxpayer contacts a tax advisor requesting advice as to the most advantageous way to dispose
of a stock, the tax advisor is faced with
A) a restricted-fact situation.
B) a closed-fact situation.
C) an open-fact situation.
D) a recognized-fact situation.
Answer: C
Page Ref.: C:1-2
Objective: 1
3) Investigation of a tax problem that involves a closed-fact situation means that
A) the client's transactions have already occurred and the tax questions must now be resolved.
B) the client's tax return has yet to be filed.
C) future events may be planned and controlled.
D) research is primarily concerned with applying the law to the facts as they exist.
Answer: A
Page Ref.: C:1-2
Objective: 1
4) Explain the difference between a closed-fact and open-fact situation.
Answer: In a closed-fact situation, the transaction has occurred and the facts are not subject to change. In
an open-fact situation, the transaction is in the formative or projected stage, and the taxpayer is able to
structure the facts so that the tax consequences of the transaction can be more favorable.
Page Ref.: C:1-2
Objective: 1
5) In all situations, tax considerations are of primary importance. Do you agree or disagree? Support your
answer.
Answer: It is important to consider nontax objectives as well as tax objectives. For instance, if a wealthy
client wants to minimize her estate taxes while passing the greatest value possible to her descendants,
you would not suggest that she leave the majority of her estate to charity and only a few hundred
thousand dollars to her descendants. Although this would reduce her estate tax liability to zero, it would
be inconsistent with her objective of allowing her descendants to receive as much after-tax wealth as
possible.
Page Ref.: C:1-2; Example C:1-2
Objective: 1
1) Identify which of the following statements is true.
A) Tax planning is an integral part of both closed-fact situations and open-fact situations.
B) The first step in conducting tax research is to clearly understand the issues involved.
C) The Statements on Standards for Tax Services recommend that only written tax advice be provided to
the client in all situations.
D) All of the above are false.
Answer: C
Page Ref.: C:1-3 through C:1-5
Objective: 2
2) Describe the format of a client memo.
Answer: A client memo should include a statement of the facts, a list of issues, a discussion of relevant
authority, analysis, and recommendations of appropriate actions to the client based on the research
results.
Page Ref.: See Additional Comment page C:1-4
Objective: 2
3) Outline and discuss the tax research process.
Answer: 1) The facts must be determined. However, some facts may not have occurred in an open-
fact situation. Where facts have not yet occurred, it is useful to review tax research material to determine
which facts would produce the most favorable outcome.
2) The issues must be determined. The issues may not always be clear and may be different than the
client believes. Thus, only a thorough understanding of the facts permits an adequate formulation of the
issues.
3) Determine which authorities are applicable.
4) Evaluate the authorities. Choose the ones to follow when there are conflicting authorities.
5) Communicate the result to the client. The communication with the client should not result in a
misunderstanding. While discussions with the client may be suitable, it is recommended by the AICPA's
Statements on Standards for Tax Services that the communication be written where issues are important,
unusual or complicated. Many firms require that conclusions be communicated in writing.
Page Ref.: C:1-4
Objective: 2
LO3: Importance of the Facts to the Tax Consequences
1) The Internal Revenue Code of 1986 contains the current version of the tax law.
Answer: TRUE
Page Ref.: C:1-8
Objective: 4
2) Regulations issued prior to the latest tax legislation dealing with a specific Code section are still
effective to the extent they do not conflict with the provisions in the new legislation.
Answer: TRUE
Page Ref.: C:1-9
Objective: 4
3) Final regulations have almost the same legislative weight as the IRC.
Answer: TRUE
Page Ref.: C:1-10
Objective: 4
4) A revenue ruling is issued by the Internal Revenue Service only in response to a verbal inquiry by a
taxpayer.
Answer: FALSE
Page Ref.: C:1-12
Objective: 4
5) Taxpayers must pay the disputed tax prior to filing a case with the Tax Court.
Answer: FALSE
Page Ref.: C:1-14
Objective: 4
6) Appeals from the U.S. Tax Court are to the Court of Appeals for the Federal Circuit.
Answer: FALSE
Page Ref.: C:1-14
Objective: 4
7) Appeals from the Court of Appeals go to the Supreme Court under a writ of certiorari. The Supreme
Court decides whether or not they will hear the case.
Answer: TRUE
Page Ref.: C:1-14
Objective: 4
8) When the Tax Court follows the opinion of the circuit court of appeals to which the case is appealable,
the court is following the
A) Golsen rule.
B) Acquiescence rule.
C) Forum shopping rule.
D) Conformity rule.
Answer: A
Page Ref.: C:1-21
Objective: 4
9) Which of the following citations denotes a regular decision of the Tax Court?
A) 41 TCM 1272
B) 35 T.C. 1083 (2003)
C) 39 AFTR 2d 77-640
D) all of the above
Answer: B
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