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I want to know if you can do this assignment for me. You need to pick one topic and write a tax memorandum. Can you

I want to know if you can do this assignment for me. You need to pick one topic and write a tax memorandum. Can you please do this for me. image text in transcribed

Tax Research Fact Scenarios Assignment: Pick from one of the following scenarios, research the issue(s) in RIA, and write a Research Memorandum giving your findings and recommendations. Use Appendix A as your guide. Please turn in the Memorandum only, and not the work papers. 1. Paul Preppie is an accountant for the Very Big (VB) Corporation of America, located in Los Angeles, California. When Paul went to work for VB, he did not have a college degree. VB required that Paul earn a B.S. degree in accounting, so he enrolled in a local private university's night school and obtained the degree. VB Corporation does not reimburse employees for attending night school, and because Paul attended a private university, the tuition and other costs were relatively expensive. Can Paul deduct any of the $5,500 he paid in tuition and other costs during the current tax year? Prepare (in good form) a research memorandum to the file. 2. Several years ago, Carol Mutter, a cash-basis taxpayer, obtained a mortgage from Weak National Bank to purchase a personal residence. In December 2009, $8,500 of interest was due on the mortgage, but Carol had only $75 in her checking account. On December 31, 2009, she borrowed $8,500 from Weak Bank, evidenced by a note, and the proceeds were deposited in her checking account. On the same day, Carol issued a check in the identical amount of $8,500 to Weak Bank for the interest due. Is the interest expense deductible for the 2009 tax year? Prepare (in good form) a research memorandum to the file. 3. Phyllis maintained an IRA account at the brokerage firm ABC. On February 11 of the current year, she requested a check for the balance of her account. She received the check made out in her name and deposited it the same day in a new IRA account at the brokerage firm XYZ. Phyllis then requested a check on May 8 from XYZ, which was deposited in another new IRA account thirty-five days later. Is the May 8 distribution taxable to Phyllis? Prepare in good form a research memorandum to the file. 4. Crystal Eros is a devout Pyramidist and a member of the Religious Society of Yanni, a Pyramidist organization. She adheres to the fundamental tenets of Pyramidist theology, including the belief that the Spirit of God is in every person and that it is wrong to kill or otherwise harm another person. Crystal's faith dictates that she not voluntarily participate, directly or indirectly, in military activities. Because Federal income taxes fund military activities, Crystal believes that her faith prohibits her from paying such taxes. Is there any legal substantiation for Crystal's position? Prepare (in good form) a research memorandum to the file. 5. Last year, your client, Robert Dinero, mailed an automatic extension for his tax return on April 15. He enclosed a check for $10,000 with the extension request. The IRS cashed the check on April 28. Later, the IRS assessed Robert late filing penalties of $2,900 because they claim he did not mail the extension request on time. On the same date, Robert mailed an income tax extension request and check to the state of California. The California check was cashed on April 16. You requested that the IRS send you a copy of the extension request envelope showing the postmark: however, the IRS has lost it. The IRS recently attached Robert's bank account for the $2,900, thereby seizing the funds directly. You have known Robert for years, and he could be described as a good law-abiding, taxpaying citizen. He always pays his taxes on time, has never been in trouble with the IRS, and is not a tax protester. Robert asks you to recommend whether he should engage a tax attorney and sue for a refund, knowing that the legal fees for such an action will probably exceed $10,000. After appropriate research, write a letter to Robert explaining your findings. Prepare (in good form) a research memorandum to the file. 6. Your client, Luther Lifo, is an auditing professor who runs a CPA review course. He comes to you with the following tax questions. Question One. Luther teaches CPA review courses on either a guaranteed or nonguaranteed basis. Under the guaranteed program, students pay higher tuition, and if they fail the CPA examination, are entitled to a full refund within two weeks of the release of the results. The CPA review course contracts require him to place the tuition in a set-aside escrow account until the students pass the exam; he established the savings account as a trust account for this purpose. The registration fee and tuition must be paid in full before the classes begin. Thus, students enrolled in the class that started in January 20x1 paid their tuition in December 20x0. In 20x0, Luther deposited registration fees and tuition, including $30,000 in guaranteed tuition payments for the winter 20x1 courses, into a checking account. Also during 20x1, he paid refunds to guaranteed students who failed the 20x1 exams from that account. Does Luther report the $30,000 as income in 20x0 or 20x1? How are the refunds paid in 20x1 treated for tax purposes? State the authority for your conclusion. Question Two. Luther is a majority shareholder in a corporation that owns an office building. He leases space in the building for use in his CPA review course. Luther pays approximately $20 per square foot in annual rent. The corporation leases the remaining space in the building to a LSAT, GMAT, SAT, and GRE review course run by other taxpayers for approximately $10 per square foot. Luther's main intent in negotiating the discounted lease was to secure the additional traffic generated by the other review courses in order to enhance the potential revenue for the CPA review course. What is the amount of rent that Luther can deduct in connection with the CPA review course? State the authority for your conclusion. Prepare (in good form) a research memorandum to the file. 7. Austin Towers is a convicted former spy for the former Soviet Union. Austin received a communication from a Soviet agent that $2 million had been set aside for him in an account upon which he would be able to draw. Austin was told that the money was being held by the Soviet Union, rather than in an independent of third-party bank or institution, on the petitioner's behalf. Over the next few years, Austin drew approximately $1 million from the account. During that period, Austin filed annual tax returns with his wife showing taxable income of approximately $65,000 per year. Conduct appropriate research to determine Austin's tax liability for the $1 million in spy fees. Prepare (in good form) a research memorandum to the file. 8. The Reverend Shaman Oracle is an ordained minister in the Church of Prophetic Prophecy in Palm Desert, California. In the current year, Shaman receives payments from the church for his services of $150,000. Of this amount, the church designates $60,000 for compensation and $90,000 as a housing allowance. Shaman and his wife own a home and have actual expenditures during the year for the home of $72,000. The house is located in a well-established rental market, and the fair rental value of the home for the current year is $55,000. Shaman wants to know how he and his wife should report these amounts on their current year's tax return. Prepare (in good form) a research memorandum to the file. 9. Your client, Teddy Chow and his wife Abby, filed a lawsuit to recover damages for personal injuries Teddy sustained in a 2000 auto accident. In 2004, a jury awarded Teddy $1,620,000 in damages. In addition, delay damages in the amount of $1,080,000 were then added to that award, resulting in a total judgment of $2,700,000. The defendant appealed the award, and while the appeal was pending, the parties reached a settlement, which provided for payment to Teddy of $2,550,000. In 2009, after attorney's fees of $850,000 were subtracted, Teddy received $1,700,000. Teddy wants to know how these amounts are treated for tax purposes. Prepare (in good form) a research memorandum to the file. 10. Cabrito Ranch, Inc. is a family ranch owned and operated by two brothers, Billie and Bubba Cabrito. The corporation made in-kind bonus payments in the form of goats to its two officers (Billie and Bubba) in exchange for their performance of agricultural labor. The two brothers are the only employees to receive goat bonuses. The transfers of the goats to the officers occurred within days of the date Cabrito Ranch would have sold the goats within the ordinary course of its business. The two officers/brothers did not market their bonus goats separately from other Cabrito Ranch goats; rather, the bonus goats were loaded onto the same trucks and sold to the same goat buyer on the same terms as other Cabrito Ranch goats. The officer/brothers' goats were sold for $70,000 ($35,000 to each brother). Cabrito Ranch wants to know how to treat the cash from the goat bonuses for FICA purposes. Prepare (in good form) a research memorandum to the file. 11. Gwen Gullible was married to Darrell Devious. They were divorced two years ago. Three years ago (the year before the divorce), Darrell received a $250,000 retirement plan distribution, of which $50,000 was rolled over into an IRA. At the time, Gwen was aware of the retirement funds and the rollover. The distribution was used to pay off the couple's mortgage, purchase a car, and for living expenses. Darrell prepared the couple's joint return, and Gwen asked him about the tax ramifications of the retirement distributions. He told her he had consulted a CPA and was advised that the retirement plan proceeds used to pay off a mortgage were not taxable income. Gwen accepted that explanation and signed the return. In fact Darrell had not consulted a CPA . One year ago (after the divorce), Gwen received a letter from the IRS saying they had not received the tax return for the last full year of marriage. On advice from a CPA, Gwen immediately filed the return (She had a copy of the unfiled return). The Internal Revenue Service notified Gwen that no estimated payments on the retirement distribution had been paid by Darrell, and that she owed $60,000 in tax, plus penalties and interest. The deficiency notice provided that the retirement distribution, less the amount rolled, was income to the couple. Prepare (in good form) a research memorandum to the file. 12. Pealii Loligo owned and operated three \"House of Calamari\" restaurants from 1998 through 2000. His wife, Cleopatra Decacera, assisted with the management of the restaurants. In May 1999, Ms. Decacera and Mr. Loligo purchased a $900,000 home. In relation to this home purchase, in 1996 and 2000 they signed mortgage loan applications indicating joint annual incomes of $235,000 and $321,000, respectively. On their 1998 joint Federal income tax return, however, Ms. Decacera and Mr. Loligo reported that they earned no salaries and had net losses of $55,000; and on their 1999 joint tax return, they reported that Mr. Loligo earned a salary of $23,000, and they had net losses of $77,000. During 1998-2000, Ms. Decacera and Mr. Loligo paid approximately $70,000 for home furnishings, $30,000 for a swimming pool, and $40,000 for Ms. Decacera's jewelry. In addition, they leased two Mercedes-Benz automobiles and took Ms. Decacera's parents on vacation to Florida and Nevada. In 2003, Decacera and Loligo were indicted and charged with filing false tax returns in 1998-2000. Loligo pled guilty, while Decacera signed a deferred prosecution agreement and admitted filing false returns. The couple divorced in 2005, and in 2006, the IRS issued a deficiency notice for the 1998-2000 taxes. In September 2006, Ms. Decacera filed a petition in which she requested relief from joint and several liability for 1998-2000 income taxes. During January 2007, Mr. Loligo filed his \"notice of intervention.\" In July, an IRS Appeals officer determined that Ms. Decacera did not qualify for Innocent Spouse relief under 6015 (f). Prepare in good form a research memorandum to the file. 13. Phred Phortunate, won his state lotto two years ago. His lotto ticket was worth $10,000,000, which was payable in twenty annual installments of $500,000 each. Phred paid $1.00 for the winning ticket. The lotto in Phred's state does not allow winners to receive their payout in a lump-sum. Phred wanted all of his money now, so he assigned his future lotto winnings to a Happy Finance Company for a discounted price of $4,500,000. Assignment of lotto winnings is permitted by Phred's state lotto. Phred filed his tax return and reported the assignment of the lotto winnings as a capital gain ($4.5M-$1.00) taxable at a 15 percent rate. After appropriate research to determine if Phred correctly reported his lotto winnings. Prepare (in good form) a research memorandum to the file. 14. Your client, Gary Gearbox, wholly owned and worked full time for a C corporation in the business of repairing autos. His wife, Tammy, wholly owned and worked full time for another C corporation that provided mobile auto windshield repairs. Both corporations' offices were located in the Gearboxes' home. The corporations paid the Gearboxes rent for the use of this office space. In addition to renting this portion of their home, the Gearboxes also owned five rental properties. On their last three tax returns, the Gearboxes reported a net income from leasing office space to their C corporations of $40,000, $24,000, and $22,000, respectively. During these years, the combined losses from the five other rental properties exceeded the income derived from their office leases. On their last three tax returns, the Gearboxes offset the losses from the rental properties against the income from the office leases and, as a result, paid no tax on the rental income paid to them by their corporation. Prepare (in good form) a research memorandum to the file

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