Norse Co, an calendar-year taxpayer received a check for $180,000 in payment for services rendered as a commissioned sales agent near the end of 2017. in 2018, the customer discovered that the commission was incorrectly computed on the sale, and Norse Inc. refunded $30,000of the $180,000 to the customer.
Norse Inc. (a C corporation) was in a 35% tax bracket in 2017, but in 2018 due to the Tax Cuts and Jobs Act is now in a 21% bracket in 2018. Since Norse was taxed on the full $180,000 under the claim of right doctrine, it may deduct the $30,000 in 2018, but this will not "make them whole."
Please research and identify the authority which would provide them relief.
Instructions:

Using RIA checkpoint, identify the issue in one of the tax services

Identify statutory authority

Identify regulatory authority

Prepare a tax research memo

Cite primary authority

Use proper citation in end notes to the memo

Written assignments will be graded on:

Identifying the correct authority

Indicate an understanding of the application of the correct authority to the question

Use of proper citation

Appropriate grammar.