Federal Taxation 2013 7th Edition Pratt Test Bank

School Work

27 pages

Please download to get full document.

View again

of 27
All materials on our website are shared by users. If you have any questions about copyright issues, please report us to resolve them. We are always happy to assist you.
Federal Taxation 2013 7th Edition Pratt Test Bank Full clear download ( no error formatting) at:https://goo.gl/As5Q9z
  Federal Taxation 2013 7th Edition Pratt Test Bank  Full clear download ( no error formatting) at: http://testbanklive.com/download/federal-taxation-2013-7th-edition- pratt-test-bank/     2 Tax Practice and Research Solutions to Tax Research Problems 2-23   a. CA-7. This information is shown in the citation for the case.  b. No. There is no Supreme Court citation listed. c. Tax Court and reported as a memorandum decision, as shown in the citation of the case. 2-24   It would be difficult to tell from the Citator alone exactly what effect the decision in  Arkansas Best v. Comm. had on the Corn Products, v. Comm. case. For example, in the Prentice Hall Citator  Arkansas Best and Corn Products are referenced by the symbol k, which stands for the cited and citing case  principles are reconciled. It is probably best to read the two cases to see how they interrelate. The Citator does alert the reader to the fact that both cases address the same issue, however. 2-25 a. The United States Court of Appeals for the Eleventh Circuit (CA-11) decided the  Robert Autrey, Jr. v. United States case on appeal.  b. A United States District Court originally tried the case. c. The Court of Appeals affirmed  part of the District Court's decision and reversed  part of it. 2-26 a. The U.S. Tax Court tried the case of Fabry v. Commissioner.  b. The judge used the following sources in framing his opinion:  (1)   Internal Revenue Code § 104; (2)   Legislative History to § 104  —  83rd Cong., 2nd Sess. 15 (1954); (3)   Various case citations; and (4)   S.Rept. 1622, 83rd Cong, 2nd Sess. 15-16 (1954). 2-27 a. No. The government won the case.  b. Judge Atkins. c. Whether operating a farm with breeding cattle and incurring net losses qualified as a business activity and therefore the net losses were deductible, or as a hobby and therefore the losses were not deductible. 2-28 a. 1998-51 I.R.B. 6  b.  Lawrence W. McCoy, 38 T.C. 841 (1962) c.  Reginald Turner, 13 TCM 462, T.C. Memo 1954-38 d.  RCA Corp. v. U.S., 81-2 USTC ¶9783 (CA-2, 1981) e.  RCA Corp. v. CAS., 48 AFTR2d 6164 (CA-2, 1981) f.  RCA Corp. v. U.S., 664 F.2d 881 (CA-2, 1981) g. Conim. v. JF J / COJC ,   66 S. Ct. 546 (USSC, 1946) h. Thor Power Tool, 79-1 USTC ¶9139 (USSC, 1979) i.  M.G. Anton, 34 T.C. 842 (1960)  j.  Brian E. Knutson, 60 TCM 540, T.C. Memo 1990-440 k. Samuel B. Levin v. Comm., 43 AFTR2d 79-1057 (Ct. Cls., 1979) 2-29 a. Issue: Whether Battelstein Investment Company unreasonably accumulated earnings so as to be subject to the § 531 accumulated earnings tax.  b.  Issue 1: Whether Code § 1034 fixes which of several sequential sales (within the statutory replacement period) is entitled to the benefit-of-gain exclusion on  the sale of a taxpayer's principal residence. Full cite is 47 TCM 904. Issue 2: When gain goes unrecognized under § 1034(a), does § 1034(e) require that the basis of the new principal residence be reduced by the amount of the deferred gain? c.  Issue 1: Was the amount paid to the taxpayer a dividend taxable as ordinary income, or was the transaction a redemption (i.e., treated as a sale-purchase)  by the corporation of all of the taxpayer's stock? Issue 2: Was the payment in question essentially equivalent to a dividend? Issue 3: Was the payment in question a complete termination of the taxpayer/shareholder's interest, and therefore, to be treated as a qualifying redemption (i.e., sale)? d. Issue: Whether Code § 704(d) allows a former partner to deduct his payment to the partnership of a portion of his distributive share of partnership losses, which was not previously deductible while he was a partner because the basis of his partnership interest was zero. e.  Issue: Whether the taxpayer permitted its earnings and profits to accumulate  beyond the reasonable needs of the business. (Note that this case is similar to the  Battelstein Investment Co. case cited in a above.) f.  Issue 1: Whether the taxpayer is entitled to an interest deduction under Code § 163(a). Issue 2: Whether the incorporating shareholders' 1968 advances to the corporation (the petitioner in this case) are considered bona fide loans or contributions to capital. g. Permanent citation should be 1985-1 C.B. 184. Issue 1: Whether a grantor's receipt of the entire corpus of one irrevocable trust in exchange for an unsecured promissory note given to the trustee, the grantor's spouse, constituted an indirect borrowing of the trust corpus that caused the grantor to be the owner of the entire trust under § 675(3). Issue 2: To the extent that a grantor is treated as the owner of a trust, whether the trust will be recognized as a separate taxpayer capable of entering into a sales transaction with the grantor. h. Permanent citation should be 1985-2 C.B. 716. This Revenue Procedure increases the operational standard mileage rate for the business use of an automobile and for when the automobile is used to render gratuitous service to a charitable organization. i. Permanent citation should be 84 T.C. 210.  Issue 1. Whether the taxpayers were engaged in an enterprise entered into for  profit or whether their activity amounted to a hobby. Issue 2. Whether certain nonrecourse notes may be included in the basis of equipment acquired by the taxpayer.  j. Permanent citation should be 1986-2 C.B. 62. Issue: Under a given set of circumstances, may a lump sum cash distribution from a deferred plan be rolled over tax-free into an IRA? k. Permanent citation should be 106 U.S. 522. Issue: May a casino, on the accrual basis, deduct amounts guaranteed for  payment on progressive slot machines but not yet won by playing patrons? 1. Issue: Issues relating to a spin-off of a corporate subsidiary. 2-30   T should be advised that he is not eligible for an office in the home deduction. Section 280A provides that a taxpayer may take expenses incurred in the use of his or her home for business purposes if such expenses are attributable to the  portion of the home used exclusively and regularly as 1.   The principal place of business for any trade or business of the taxpayer; 2.   A place of business that is used by patients, clients, or customers in meeting or dealing with the taxpayer in the normal course of his or her trade or business; or 3.   A separate structure, not attached to the dwelling unit, that is used in the taxpayer's trade or business. First, this taxpayer probably fails the exclusive use test by using the den of his home for his work. The exclusive use test is strictly interpreted, so the use of the business portion of a home by the taxpayer or members of his family for  purposes not related to business will result in the disallowance of the business expense deductions. Second, this taxpayer does not use his home office as the  principal place of business in meeting or dealing with patients, clients, or customers in the normal course of his trade or business. It appears that the work the taxpayer brings home is simply additional work connected to the work he does during the day at the office. Third, the taxpayer has an office provided by his employer available to him at all times. There is case precedent holding that lack of amenities during the weekend and after hours does not produce an office in the home deduction for a taxpayer who chooses to work at home rather than in his or her office. Because this is the first legal research problem the student has ever done, the
We Need Your Support
Thank you for visiting our website and your interest in our free products and services. We are nonprofit website to share and download documents. To the running of this website, we need your help to support us.

Thanks to everyone for your continued support.

No, Thanks

We need your sign to support Project to invent "SMART AND CONTROLLABLE REFLECTIVE BALLOONS" to cover the Sun and Save Our Earth.

More details...

Sign Now!

We are very appreciated for your Prompt Action!