1. An example of the administrative convenience concept is the IRSs announce-ment that the value of frequent flyer miles earned for business travel need not be included in the recipients gross income. Based on the IRSs stated rationale in Announcement 2002-18, do you believe that the same rule would apply to miles earned for personal travel? Why or why not?

2. Mr. Grifter embezzles $150,000 from his employer. He gets caught . . . but only after having spent much of that money. Is Mr. Grifter properly taxable on that $150,000 i.e., should it be included in his gross income for FIT purposes? Why or why not?

3. The board of directors of ABC Corp. meets on December 15th, Year 1, and ap-proves the immediate payment of a $2.5 million cash bonus to Ms. Executive. She (Ms. Executive) goes immediately to ABCs treasurer and asks that her bo-nus check not be prepared and delivered to her until January 2, Year 2. The trea-surer says Well, I was just about to prepare it, but okay!.

As ABC Corp.s Tax Director, what advice do you give to ABCs treasurer regard-ing when the $2.5 million should be reported to the IRS i.e., as part of Ms. Exe-cutives Year 1 pay or her Year 2 pay, and why?

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