Pearson's Federal Taxation 2025
Corporations, Partnerships,
Estates, & Trusts, 38th Edition by
Luke E. Richardson
Complete Chapter Solutions Manual
are included (Ch 1 to 15)
** Immediate Download
** Swift Response
** All Chapters included
,Table of Contents are given below
1.Tax Research
2.Corporate Formations and Capital Structure
3.The Corporate Income Tax
4.Corporate Nonliquidating Distributions
5.Other Corporate Tax Levies
6.Corporate Liquidating Distributions
7.Corporate Acquisitions and Reorganizations
8.Consolidated Tax Returns
9.Partnership Formation and Operation
10.Special Partnership Issues
11.S Corporations
12.The Gift Tax
13.The Estate Tax
14.Income Taxation of Trusts and Estates
15.Administrative Procedures
,Solutions Manual organized in reverse order, with the last chapter
displayed first, to ensure that all chapters are included in this
document. (Complete Chapters included Ch15-1)
Chapter C:15
Administrative Procedures
Discussion Questions
C:15-1 IRS Service Centers verify the tax calculation. They check to see whether amounts are
properly carried from one line to another on the return and whether items such as signatures or social
security numbers are missing. p. C:15-3.
C:15-2 The IRS issues revenue rulings, revenue procedures, letter rulings, determination letters,
announcements, notices, and information releases. p. C:15-2.
C:15-3 a. The IRS has gathered data to develop its DIF statistical models through two
programs: (1) the Taxpayer Compliance Measurement Program (TCMP) and (2) the National
Research Program (NRP).
b. The TCMP was based on special audits of all line-by-line items; the NRP is based on
pre-existing audit data as well as data compiled in ordinary audits of portions of tax returns.
c. The IRS has used these models to identify tax returns with items that significantly
depart from a statistical norm, and thus flag the returns for examination. p. C:15-4.
C:15-4 Ben’s, because it includes a number of items that probably depart from the DIF statistical
norm. Al’s, however, has a large number of exemptions plus a loss that the IRS might think is a
nondeductible hobby loss. pp. C:15-4 and C:15-5.
C:15-5 No. Even though the IRS audited his return for two years earlier, that audit dealt with a
different issue. Therefore, the IRS can challenge the interest expense deduction on the current year
return. pp. C:15-5 and C:15-6.
C:15-6 Brad has the following alternatives:
• Brad may agree that he owes the additional taxes; if so, he may sign Form 870
(Waiver of Statutory Notice) if requested.
• He may ask to meet with the examining agent’s supervisor.
• If the matter is complex and highly technical, Brad may urge the IRS employee to
seek technical advice from the IRS’s national office.
• He may meet with an appeals officer.
• He may file a petition with the Tax Court without paying the deficiency.
• After being notified of the deficiency, he may pay the taxes and file for a refund in a
U.S. district court or the U.S. Court of Federal Claims.
pp. C:15-6 through C:15-8.
, C:15-7 a. Taxpayer has 30 days from the date of the letter to request a conference with an IRS
appeals officer, or to file a protest letter.
b. Taxpayer has 90 days from the date of the letter to file a petition with the Tax Court.
c. Taxpayer has two years to sue the IRS for a refund in a U. S. district court or the
U.S. Court of Federal Claims. pp. C:15-6 through C:15-8.
C:15-8 A taxpayer can initiate litigation in the Tax Court, the U.S. Court of Federal Claims, or a
U.S. district court. pp. C:15-7 and C:15-8.
C:15-9 Taxpayers frequently litigate in the Tax Court because, to access it, they do not have to pay
the amount in question and in certain circumstances can use the small cases procedure. However,
taxpayers cannot appeal decisions of the small claims division. Also, the Tax Court has greater tax
expertise than the other courts have. pp. C:15-7 and C:15-8.
C:15-10 Protest letters are necessary if the amount of additional tax plus penalties and interest in
question exceeds $25,000. p. C:15-6.
C:15-11 A statement of all relevant facts including:
• Names, addresses, telephone numbers, and taxpayer identification numbers of all
interested parties
• The taxpayer’s annual accounting period and method
• A description of the taxpayer’s business operations
• A complete statement of the business reasons for the transaction.
• A detailed explanation of the transaction
• All other facts relating to the transaction or to the taxpayer’s requested tax treatment.
See Rev. Proc. 2024-1, I.R.B. 2024-1, Sec. 7.01.
Copies of all pertinent contracts, agreements, and other documents that affect the transaction also
should be included. p. C:15-9.
C:15-12 Four conditions must be met, as follows:
• Taxpayer must introduce credible evidence regarding the issue.
• Taxpayer must comply with the recordkeeping and substantiation requirements of the
IRC.
• Taxpayer must cooperate with reasonable IRS requests for witnesses, information,
documents, meetings, and interviews.
• Taxpayer must be either a legal person with net worth not exceeding $7 million or a
natural person. pp. C:15-8 and C:15-9.
C15-13 The IRS will rule on estate tax matters for a decedent if the estate tax return has not been
filed. It also will rule on the estate tax consequences of transactions of a living person. No requests
will be considered, however, with respect to prospective estate tax rulings involving computations of
tax, actuarial factors, and factual matters (Rev. Proc. 2024-1, I.R.B. 2024-1, 1, Sec. 5.06).
p. C:15-10.
