Question
1. Jim Harvey, your client, owns a life insurance policy on his own life. He has paid $6,500 in premiums, and the cash surrender value
1. Jim Harvey, your client, owns a life insurance policy on his own life. He has paid $6,500 in premiums, and the cash surrender value of the policy is $25,000. Jim Harvey borrowed $25,000 from the insurance company, using the cash surrender value as collateral. He is considering canceling the policy in payment of the loan. Jim Harvey would like to know the federal income tax consequences of canceling his insurance policy. Discuss the tax implications.
2. As we know, Congress devised a very broad definition of income and codified this definition in Section 61 of the Internal Revenue Code. Explain the Code's definition of income and how it is generally applied to taxpayers. In particular, explain how the Code's definition of income is different than other potential definitions of income, such as the economic concept of income, and use an example to illustrate the difference between the two systems.
3. In terms of revenue neutrality, comment on a tax cut enacted by Congress that also contains revenue offsets, a tax cut enacted by Congress that is phased in over a period of years, a tax cut enacted by Congress that contains a sunset provision & a tax cut enacted by Congress that includes a stealth tax feature
4. Should funds borrowed against your insurance policy be taxable? Why? Why not?
5. What are the tax implications when the taxpayer gets monies from insurance companies? Discuss.
6. Explain the function of Temporary Regulations.Compare a determination letter with a letter ruling.
7. Discuss the advantages and disadvantages of the Small Cases Division of the U.S. Tax Court.
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