Federal taxation

Federal taxation 1. The first two assignments require you to compose tax file memoranda. In each of these problems, you will be given a fact pattern or issue that requires you to decide or analyze a particular issue of tax law. You will also be provided with a number of the primary sources discussed above (e.g., Revenue Rulings, cases) on that issue of tax law. You will then compose a tax file memoranda concerning that taxpayer. You can find details as to how to compose such a memorandum in Chapter 2 of your text, including a sample text file memorandum in Figure 2.6 on page 2-26 of your text. Use the materials provided to determine the proper solution to the taxpayer’s issues. In particular, discuss the materials in some detail in the “Analysis” section of the tax file memorandum. THIS IS IMPORTANT! The most important part of any tax file memorandum is the thoroughness of the analysis defending the conclusion reached in the memorandum. Accordingly, most of the points awarded on the assignment are allocated to the “Analysis” section of the memorandum. In assessing these assignments, consideration will be given to, among other factors, (1) your accuracy in summarizing the relevant facts; (2) the accuracy of your identification and statement of the “Issue” presented by the problem; (3) the accuracy of your “Conclusion;” (4) the thoroughness and quality of your analysis

offered in the “Analysis” section of your memorandum; and (5) the overall professionalism of your memorandum (e.g., presentation, use of proper grammar, proper spelling, and quality of communication). EACH OF THE TAX MEMORANDA IS WORTH 30 POINTS, FOR A TOTAL OF 60 POINTS.

  1. The remaining assignment requires you to perform some research on the Internet to find relevant materials and to analyze these materials. As previously noted, in performing this research, you may not take advantage of any resources other than those specifically permitted by the assignment, including assignments previously completed by other students or other similar materials. You will then complete an essay answering the question or questions presented by this assignment. Your submission will be graded on a number of factors, including (1) your ability to locate relevant research and materials on the Internet; (2) your ability to analyze these resources; (3) your ability to draw conclusions from these resources and to defend these conclusions with analysis of the research and materials located; and (4) the overall professionalism and content of your essay (e.g., presentation, use of proper grammar, proper spelling, and quality of communication). THIS ESSAY IS WORTH 20 POINTS.

Please note that these assignments are worth a significant portion of your grade. As such, you should take them seriously, and leave yourself enough time to complete them. Do not wait until the last weekend to begin these assignments. If you do, it will be very difficult for you to submit quality responses to each of the four questions or problems posed. Please also note that preparing these answers conscientiously will help you in preparing for the final examination, given that you may be required to perform similar analyses on the exam. Should you have a question, please ask your instructor.

WEEK 7 RESEARCH PROJECT

(Set #1)

ACCT 429

Performing tax research is an important part of tax practice.  As outlined in Chapter 2 of your textbook, tax law is developed through a number of different governmental entities.  Congress enacts the tax Code as statutory law.    The Treasury Department is tasked with the implementation  of  the  tax  Code  and,  in  the  course  of  doing  so,  develops  a  number  of documents and materials to aid taxpayers in understanding the Treasury Department’s interpretation of the code, including the Regulations.  In turn, the Internal Revenue Service (“IRS”)  has  the  direct  responsibility  for  implementing  the  tax  Code  and  in  assessing  and collecting the applicable tax from taxpayers.   In the course of its duties, it also develops a number  of  materials,  including  Revenue  Rulings,  Revenue  Procedures,  and  Private  Letter Rulings, in which it sets forth its understanding of the tax laws.   Finally, the federal courts decide tax cases in which taxpayers contest the government’s interpretation of the tax laws.  In deciding these cases, the federal courts set forth binding interpretation of what the tax laws provide.  All of these materials (often called primary resources) are important resources in performing tax research.  On top of these primary sources of tax law, there are a number of secondary materials provided by various organizations and publishers.   These secondary materials offer editorial analysis of the tax laws (somewhat akin to a Cliffs’ Notes® on tax laws) to help tax practitioners understand the tax laws and apply them in given situations.

 

Just as with the first project that was submitted in Week 3, the following assignment has three (3) different graded elements.  Two of them require you to prepare tax file memoranda, while the remaining element requires you to compose an essay answering the question asked.  AS SUCH, YOU WILL BE SUBMITTING THREE SEPARATE DOCUMENTS FOR THIS ASSIGNMENT.

 

The first two assignments require you to compose tax file memoranda.  In each of these problems, you will be given a fact pattern or issue that requires you to decide or analyze a particular issue of tax law.  You will also be provided with a number of the primary sources discussed above (e.g., Revenue Rulings, cases) on that issue of tax law.  You will then compose a tax file memoranda concerning that taxpayer.  You can find details as to how to compose such a memorandum in Chapter 2 of your text, including a sample text file memorandum in Figure 2.6 on page 2-26 of your text. Use the materials provided to determine the proper solution to the taxpayer’s issues.   In particular, discuss the materials in some detail in the “Analysis” section of the tax file memorandum.  THIS IS IMPORTANT! The most important part of any tax file memorandum is the thoroughness of the analysis defending the conclusion reached in the memorandum.   Accordingly, most of the points awarded on the assignment are allocated to the “Analysis” section of the  memorandum.    In  assessing  these  assignments, consideration  will  be  given to, among other factors, (1) your accuracy in summarizing the relevant facts; (2) the accuracy of your identification and statement of the “Issue” presented by the problem; (3) the accuracy of your “Conclusion;” (4) the thoroughness and quality of your analysis
offered in the “Analysis” section of your memorandum; and (5) the overall professionalism of your memorandum (e.g., presentation, use of proper grammar, proper spelling, and quality of communication).  EACH OF THE TAX MEMORANDA IS WORTH 30 POINTS, FOR A TOTAL OF 60 POINTS.

The remaining assignment requires you to perform some research on the Internet to find  relevant  materials  and  to  analyze  these  materials.     As  previously  noted,  in performing this research, you may not take advantage of any resources other than those specifically permitted by the assignment, including assignments previously completed by other students or other similar materials.  You will then complete an essay answering the question or questions presented by this assignment.  Your submission will be graded on a number of factors, including (1) your ability to locate relevant research and materials on the Internet; (2) your ability to analyze these resources; (3) your ability to draw conclusions from these resources and to defend these conclusions with analysis of the research and materials located; and (4) the overall professionalism and content of your essay (e.g., presentation, use of proper grammar, proper spelling, and quality of communication). THIS ESSAY IS WORTH 20 POINTS.
Please note that these assignments are worth a significant portion of your grade.  As such, you should take them seriously, and leave yourself enough time to complete them.  Do not wait until the last weekend to begin these assignments.  If you do, it will be very difficult for you to submit quality responses to each of the four questions or problems posed.   Please also note that  preparing  these  answers  conscientiously  will  help  you  in  preparing  for  the  final examination, given that you may be required to perform similar analyses on the exam.  Should you have a question, please ask your instructor. Good luck!

TAX RESEARCH MEMORANDUM ASSIGNMENT 1

As we learned in Week 4, the Code allows taxpayers to take a deduction for the cost of meals when taxpayers have been deemed to be “away from home” for tax purposes.   This determination can be difficult.  Two separate clients came to you with questions as to whether they are entitled to take a deduction for the cost of meals incurred during a particular trip.  The facts pertaining to each are:

Tracey is a sales representative for a national pharmaceutical company.  She has a rather large sales territory, and she makes her rounds to her customers using a company-owned car over a 16- to 19-hour period of time.  During these one-day business trips, Tracey will pull over in a suitable location (such as a park or a rest stop) and take a short nap in the backseat of her automobile.
Mark captains a ferryboat.  This ferryboat carries tourists on roundtrips from Seattle to Victoria and back, each trip of which lasts from 15 to 17 hours and provides for a
6- to 7-hour layover in Victoria.  During the layover, Mark typically takes a four-hour nap on a cot that he has stored in the pilothouse of the ferryboat.

Under each of these circumstances, if the taxpayer entitled to deduct the cost of meals purchased during the trip at issue?

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