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).
> 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
> 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, RadioC
> 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 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
> 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
> 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.
> James Corporation believes that it will have a better distribution location for its product if it relocates the corporation to another state. What considerations (both tax and nontax) should James weigh before making a decision on whether to make the mov
> Jim, a resident of Washington (which imposes a general sales tax), goes to Oregon (which does not impose a general sales tax) to purchase his automobile. Will Jim successfully avoid the Washington sales tax? Explain.
> Distinguish between taxes that are proportional and those that are progressive.
> 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.
> In terms of Adam Smith’s canon of economy, how does the Federal income tax fare?
> Go to www.taxfoundation.org, and determine Tax Freedom Day for your state for 1950, 1960, 1970, 1980, 1990, 2000, and 2010. Report your results as a line graph.
> Contrast a value added tax (VAT) with a national sales tax in terms of anticipated taxpayer compliance.
> Discuss the probable justification for each of the following aspects of the tax law. a. A tax credit is allowed for amounts spent to furnish care for minor children while the parent works. b. Deductions for interest on home mortgage and property taxes o
> Discuss the probable justification for each of the following provisions of the tax law. a. A tax credit allowed for electricity produced from renewable sources. b. A tax credit allowed for the purchase of a motor vehicle that operates on alternative ener
> Franklin County is in dire financial straits and is considering a number of sources for additional revenue. Evaluate the following possibilities in terms of anticipated taxpayer compliance. a. A property tax on business inventories. b. A tax on intangibl
> Mauve Supplies, Inc., reports total income of $120,000. The corporation’s taxable income is $105,000. What are Mauve’s marginal, average, and effective tax rates?
> Ashley runs a small business in Boulder, Colorado, that makes snow skis. She expects the business to grow substantially over the next three years. Because she is concerned about product liability and is planning to take the company public in 2016, she is
> Marco and Cynthia have decided to go into business together. They will operate a burrito delivery business. They expect to have a loss in the first and second years of the business and subsequently expect to make a substantial profit. Marco and Cynthia a
> Several years ago, Ethan purchased the former parsonage of St. James Church to use as a personal residence. To date, Ethan has not received any ad valorem property tax bills from either the city or the county tax authorities. a. What is a reasonable expl
> 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).
> Eileen, a resident of Wyoming, goes to Montana to purchase her new automobile. She does this because Wyoming imposes a sales tax while Montana does not. Has Eileen successfully avoided the Wyoming sales tax? Explain.
> The Irontown Independent School District wants to sell a parcel of unimproved land that it does not need. Its three best offers are as follows: from the State Department of Public Safety (DPS), $4.3 million; from Trinity Lutheran Church, $4.2 million; an
> Some tax rules can be justified on multiple grounds (e.g., economic or social). In this connection, comment on the possible justification for the rules governing the following. a. Pension plans. b. Education. c. Home ownership.
