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federal tax research

Questions and Answers of Federal Tax Research

Find the court decision located at 2007-1 USTC ¶50,210.a. What court heard the case?b. Who was the judge(s)?c. What tax year(s) is in question and in what year was the case decided?d. What Code
Find the court decision located at T. C. Summary Opinion 2010-46.a. What court heard the case?b. Who was the judge(s)?c. What tax year(s) is in question and in what year was the case decided?d. What
Find the court decision located at T. C. Summary Opinion 2006-20.a. What court heard the case?b. Who was the judge(s)?c. What tax year(s) is in question and in what year was the case decided?d. What
Find the court decision located at T. C. Summary Opinion 2003-168.a. What court heard the case?b. Who was the judge(s)?c. What tax year(s) is in question and in what year was the case decided?d. What
Find the court decision located at T. C. Memo. 1992-204.a. What court heard the case?b. Who was the judge(s)?c. What tax year(s) is in question and in what year was the case decided?d. What Code
Find the court decision located at T. C. Memo. 2001-71.a. What court heard the case?b. Who was the judge(s)?c. In what year was the case decided?d. What was the issue(s) involved?
Find the court decision located at T. C. Memo 2010-54.a. What court heard the case?b. Who was the judge(s)?c. In what year was the case decided?d. What was the issue(s) involved?
Find the court decision located at 133 T. C. No. 8.a. What court heard the case?b. Who was the judge(s)?c. In what year was the case decided?d. What was the issue(s) involved?
Find the court decision located at 126 T. C. 47.a. What court heard the case?b. Who was the judge(s)?c. In what year was the case decided?d. What was the issue(s) involved?
Find the court decision located at 100 T. C. 32.a. What court heard the case?b. Who was the judge(s)?c. In what year was the case decided?d. What was the issue(s) involved?
Locate the court case Anderson Columbia, Inc. V. U.S., 54 Fed. Cl. 756 (2002). Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the court?b. What was the
Locate the court case Zimmerman, et al. v. United States, 2001-1 USTC ¶50,107, 86 AFTR2d 2000-6701.Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the
Locate the court case Angela J. Brown v. Commissioner, T. C. Summary Opinion 2010-56. Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the court?b. What
Locate the court case Alemasov and Popov, T. C. Memo. 2007-130. Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the court?b. What was the ruling of the
Locate the court case Container Corporation v. Commissioner, 134 T. C. No. 5 (2010). Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the court?b. What
Locate the court case Fisher v. Comm., 105 AFTR2d 2010-2226. Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the court?b. What was the ruling of the
Locate the court case Central Labor’s Pension Fund v. Heinz, 541 U.S. 739 (2004). Using only the headnotes answer the following questions:a. What was the issue(s) addressed by the court?b. What was
What is the common form of a citation shown in Exhibit 5-13?
By using only the citation, state which court issued each of the following decisions. If you cannot determine which court by looking at the citation only, say so.a. Douglas, Christopher, T.C. Memo
What is a case headnote? How might it be useful to the tax researcher?
By using only the citation, state which court issued each of the following decisions. If you cannot determine which court by looking at the citation only, say so.a. Davis v. U.S., 43 Fed. Cl. 92
In the citation Simons-Eastern v. U.S., 354 F.Supp. 1003 (D.Ct., Ga, 1972), the “F.Supp.” tells the tax researcher that the decision is from which court?
Which court would have issued the (fictitious) O’Dell v. U.S., 98 TCM 86 (2009) decision? What does each element in the citation mean?
In the (fictitious) citation Gomez v. U.S., 104 T. C. 123 (2009), what does the “104” stand for? The “T. C.”?The “123”?
Discuss the precedential value of a Court of Appeals decision. Which Court of Appeals decisions are most important to a specific taxpayer?
Is it possible for a taxpayer to have a jury trial before any of the trial courts? Before a Court of Appeals?Before the U.S. Supreme Court?
Name the four court case reporters that publish Supreme Court decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.
Differentiate between the Supreme Court’s overturning of a lower court’s decision and its denial of a writ of certiorari.
Why does the Supreme Court hear so few tax cases?
How many justices are appointed to the Supreme Court? How many hear each case?
How does one petition the Supreme Court to hear one’s tax case?
What is the highest court in the United States? What is its jurisdiction? Where does it hear cases?
Can a taxpayer have a jury trial before a Court of Appeals?
Name the three court case reporters that publish Court of Appeals decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the citation means.
Each Court of Appeals has approximately 20 judges. How many of these judges hear a typical case?
Identify the circuit court that would hear the case of a taxpayer who lives or works in each of the following areas:a. Missourib. Montanac. Mississippid. Massachusettse. Michigan
Identify the circuit court that would hear the case of a taxpayer who lives or works in each of the following areas:a. Arizonab. Alabamac. Vermontd. South Carolinae. Alaska
Identify the circuit court that would hear the case of a taxpayer who lives or works in each of the following areas:a. Floridab. Ohioc. North Carolinad. Puerto Ricoe. Guam
Identify the circuit court that would hear the case of a taxpayer who lives or works in each of the following areas:a. Texasb. New Yorkc. Californiad. Coloradoe. A case that is appealed from the U.S.
Are the U.S. Courts of Appeals national courts? What type of cases do they hear?
Name the three court case reporters that publish U.S. Court of Federal Claims decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the
Is the U.S. Court of Federal Claims a national court? Must a taxpayer go to Washington, D.C., to present a case to this U.S. court?
How many judges are appointed to the U.S. Court of Federal Claims?
What type of cases are heard by the U.S. Court of Federal Claims?
Differentiate between a primary and a secondary case citation.
Name the three court case reporters that publish tax and nontax District Court decisions. Illustrate the elements of a citation that might be found in each reporter. Explain what each part of the
Is a Federal District Court a national court? How many judges hear a case brought before a Federal District Court?
Which of the trial courts would best serve a taxpayer litigating an issue of a technical tax nature? Why?
Which of the trial courts is most appropriate for a taxpayer who wishes to limit the judicial review of the relevant year’s tax return to the specific issue(s) involved in the case?
Must the taxpayer pay the disputed tax deficiency to the government before his or her case will be heard in a District Court? In the U.S. Court of Federal Claims? In the U.S. Tax Court?
Can Tax Court Summary Opinions be cited as precedent? Discuss.
What is the jurisdiction of a U.S. District Court?
Tax Court Memorandum decisions are not published by the Federal government. However, commercial reporters include these decisions. Illustrate the elements of both a temporary and a permanent citation
Where are regular Tax Court decisions published? Illustrate the elements of both a temporary and a permanent regular Tax Court citation. Explain what each part of the citation means.
What is the Small Cases Division of the U.S. Tax Court? What is the maximum amount of the deficiency that can be the subject of a Small Cases hearing? Comment on the trial procedures in the Small
The U.S. Tax Court is a national court that hears cases of taxpayers who may appeal to various geographical Courts of Appeals. How does the Tax Court reconcile the opposite holdings of two or more of
Distinguish among a Regular, Memorandum, and Summary decision of the Tax Court.
What does the term “en banc” mean?
May a taxpayer have a jury trial in the U.S. Tax Court?
The U.S. Tax Court is a national court that meets in Washington, D.C. Does this mean that the taxpayer and his or her attorney must travel to Washington to have a case heard?
How many judges sit on the U.S. Tax Court? What is the length of time of the appointment of each judge?
The U.S. Tax Court has undergone an evolution since it was founded. What happened to its structure in 1926, 1943, and 1969, respectively?
The U.S. Tax Court hears only certain types of cases. Identify those cases.
Who has the burden of proof in most cases involving the tax law? Why?
May a taxpayer take his or her tax case directly to the Supreme Court?
Explain the general organization of the Federal court system for cases concerning Federal tax issues.
Who can initiate a court case that deals with a tax matter—the taxpayer or the IRS?
David Dental, DDS and his unmarried partner Sally Surgeon, MD have lived together for the past five years. Both are at the peak of their careers and decide to buy a new “show case” home in La
Your client, Manny Mendacious, invested $70,000 in the stock of a new start-up company that opened a chain of fried pickle fast-food restaurants call “the Cooked Cucumber.” As might be expected,
Your client, Mustang Racing Parts Inc. (MRP), is engaged in the production, transmission, distribution, and sale of racing headers for Ford Mustangs (inventory property). The client is also involved
Fred Forgetful parks his personal car on a hill in sunny California and fails to properly set the brake or curb the wheels. As a result of Fred’s negligence, the car rolls down the hill, damages
The Venganza Tribe is a Federally recognized Indian tribal government described in IRC §7701(a)(40)(A).The Venganza Tribe would like to invest some of its cash resulting from its newly opened casino
At age 65, Carlota’s financial position was better than her health. She had a large balance in an IRA that she wanted to move to a different IRA. Carlota withdrew $100,000 from the IRA and planned
Your client, Ned Bovine, purchased a $2 million life insurance policy from the Nickel Life Insurance Co. (NLIC) of Dime Box, Texas. Ned’s wife is the beneficiary of the policy. The policy was
The Pima and Southern Railroad (PSRR) is a small railroad operating in rural Arizona. It exists by carrying freight to remote areas of the southwest. This year the PSRR needs to replace a 30-mile
Joe Bacillus owns Bacillus’s Italian Restaurant. A friend of Joe’s who owns a sports bar comes to Joe and wants to form a partnership with Joe to buy an old building, renovate it, and then move
Alpine Corporation is a qualified small business corporation eligible to elect S corporation status. Albert is a shareholder in Alpine. On February 1 of the current year, Albert dies before signing
Shaky Savings & Loan has a depositor named Olive who opened an account last year. At that time, Olive gave Shaky her Social Security Number (SSN) as a taxpayer identification number (TIN). The IRS
Ace High and Lady Luck live together and have pooled their funds for several months to purchase food and other household necessities and to buy an occasional state lottery ticket. Ace used part of
Dieter won the lottery this year, which means that he will receive $400,000 a year for the next 30 years. The present value of Dieter’s prize is about $3,750,000. Conscious of the tax benefits of
Georgia won the Massachusetts lottery, which means that she will receive $28,000 a year for the next 30 years. Georgia purchased the lucky ticket in March, and she was selected the winner in June.
Joe incurred $38,000 of investment interest expense in the current year. He also generated $35,000 in dividend income and had a $65,000 passive loss for the year. What is the amount of Joe’s
Lance asks you to explain why his employer, the Good Food Truck Stop, an establishment that employs more than 30 waiters/waitresses, included $2,400 in tip income on his Form W-2 for the year.Lance
Are points paid by homebuyers on VA and FHA loans deductible in the year the house is purchased?Database to search: Revenue Procedures Keywords: loan, origination, fees, VA, FHA
Are homeowners who claim an itemized deduction for interest paid on adjustable rate mortgages and then receive refunds in a later year required to show the refunds as taxable income?Database to
Is a veterinary medical corporation a “personal service corporation” for purposes of the required use of the flat 35 percent tax rate?Database to search: Revenue Rulings Keywords: veterinary,
Can proceeds from a life insurance policy be included in a decedent’s gross estate if the policy was purchased by an S corporation for an employee-shareholder?Databases to search: the Code and IRS
A member of a tax-exempt business league makes deposits into a strike fund. The contribution reverts to the taxpayer if the fund is terminated. Are these deposits tax deductible?Database to search:
What is the current status of each of the following IRS pronouncements?a. Notice 2004-29b. Revenue Ruling 2004-28c. Revenue Procedure 93-15d. Announcement 99-41
What is the current status of each of the following IRS pronouncements?a. Notice 2001-26b. Revenue Ruling 2000-41c. Revenue Procedure 89-31d. Announcement 99-110
Locate the pronouncement at 2006-40 I.R.B. 528.a. What is the number assigned to this written determination?b. What is the subject matter discussed in this written determination?
Locate the pronouncement at 2007-17 I.R.B. 990.a. What is the number assigned to this written determination?b. What is the subject matter discussed in this written determination?
Locate the pronouncement at 2004-10 I.R.B. 550.a. What is the number assigned to this written determination?b. What is the subject matter discussed in this written determination?
Locate the pronouncement at 2000-2 C.B. 333.a. What is the number assigned to this written determination?b. What is the subject matter discussed in this written determination?
Locate the pronouncement at 1989-1 C.B. 76.a. What is the number assigned to this written determination?b. What is the issue(s) addressed in this written determination?c. What is the holding in this
What is the current status of each of the following Revenue Rulings?a. Rev. Rul. 2002-80b. Rev. Rul. 2001-31c. Rev. Rul. 98-13
What is the current status of each of the following Revenue Rulings?a. Rev. Rul. 95-35b. Rev. Rul. 94-17c. Rev. Rul. 87-34
For each of the following Code sections, how many Treasury Regulations have been issued? Give the total number of such Regulations and the number of the last Regulation.a. §25Ab. §119c. §180d.
For each of the following Code sections, how many Treasury Regulations have been issued? Give the total number of such Regulations and the number of the last Regulation.a. §102b. §143c. §301d.
Briefly describe the subject matter of each of the following TDs:a. T.D. 8346b. T.D. 8780c. T.D. 8915

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