Nonliquidating distributions in a partnership
Answer: Page Ref.: C:1-10 5) A revenue ruling is issued by the Internal Revenue Service only in response to a verbal inquiry by a taxpayer. Tax Court are to the Court of Appeals for the Federal Circuit. Answer: Page Ref.: C:2-32 and C:2-33 12) Upon formation of a corporation, its assets have the same bases for book and tax purposes. A) A solely owned corporation is a sole proprietorship.Answer: Page Ref.: C:1-12 6) Taxpayers must pay the disputed tax prior to filing a case with the Tax Court. Answer: Page Ref.: C:10-14 8) Appeals from the Court of Appeals go to the Supreme Court under a writ of certiorari. Answer: Page Ref.: C:2-36 13) Business assets of a sole proprietorship are owned by A) a member. B) A sole proprietorship is a separate taxable entity.Answer: Page Ref.: C:1-26 10) According to the , CPAs must verify all tax return information submitted by reviewing client documentation. A) Tax planning is an integral part of both closed-fact situations and open-fact situations. Answer: Page Ref.: C:1-7 19) Which of the following steps, related to a tax bill, occurs first? A) Paragraph references are most commonly used when citing or referring to the tax statutes. C) Proposed and temporary regulations are generally issued simultaneously. 1.199-2” refers to A) the first regulation issued in 1999. C) Partners are taxed on their allocable share of income whether it is distributed or not.Answer: Page Ref.: C:1-27 11) 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) The first step in conducting tax research is to clearly understand the issues involved. D) all of the above Answer: Page Ref.: C:1-7 15) Identify which of the following statements is . D) forwarded to the Senate Finance Committee for consideration. A) signature or veto by the President of the United States B) consideration by the Senate Finance Committee C) consideration by the entire Senate D) consideration by the House Ways and Means Committee Answer: Page Ref.: C:1-7 20) When the House and Senate versions of a tax bill are not in agreement, the disagreements are resolved by the A) Ways and Means Committee. B) Title 26 of the United States Code and the Internal Revenue Code of 1986 are synonymous. D) Proposed regulations do not provide any insight into the IRS’s interpretation of the tax law. D) subsection of the Code section being interpreted. D) Partners are considered employees of the partnership. Answer: 115) Your client wants to deduct commuting expenses on his tax return.
Tax Court to permit litigating parties to agree on the exact amount of the tax due. Tax Court allows a less formal hearing but provides for no appeal. Answer 96) Is it possible for the Tax Court to intentionally issue conflicting decisions? Answer: 106) Outline and discuss the tax research process. The client, however, continues to insist on this action. You explain to the client that there is no legal authority allowing this deduction. D) usually deal with factual variations of issues litigated previously. Answer: 112) Discuss the differences and similarities between regular and memorandum decisions issued by the U. The government appealed to the Fifth Circuit, which reversed the decision and held it was not deductible. Would your answer be different if the case was appealable to the Fifth Circuit?
Answer: Page Ref.: C:1-14 43) Tax Court memorandum decisions A) cannot be appealed. C) have less precedential value than regular decisions. B) He can appeal the case, but only if the amount of tax involved is greater than ,000. Also indicate on which pages and in which publications the authority is reported. Answer: 111) Describe the appeals process in tax litigation. Answer: 113) Assume that the Tax Court decided an expenditure in question was deductible. How will the Tax Court rule if this new case is appealable to the Tenth Circuit?
[email protected] Hall’s Federal Taxation 2013: Corporations, (Pope/Anderson/Kramer) Chapter C1 Tax Research 1) Tax planning is not an integral part of open-fact situations. Answer: Page Ref.: C:2-18 8) A corporation must recognize a loss when transferring noncash boot property that has declined in value and its stock to a transferor as part of a Sec. Answer: Page Ref.: C:2-21 9) If a corporation’s total adjusted bases for all properties transferred exceed the total FMV of the properties, the corporation’s bases in the property is limited to FMV if no election is made.