Please help me with the attached assignment.

1. Which specific part of the Internal Revenue Code defines ?qualifying relative??

1. Which Internal Revenue Code Section spells out the tax treatment for landlords (lessor) when they have improvements made by their tenants (lessee) on their rental properties?

1. We know from Chapter 6 that rental expenses are FOR AGI deductions. Find a Tax Court & Board of Tax Appeals reported decision in RIA Checkpoint that is about the deduction of the rental expenses of vacation home in 1981.

_______ v. ________ _____ TC ______

1. Where is ?capital asset? defined in the code?

1. Find the case named ?Singleton-Clarke v. Commissioner?. Summarize the reason why the taxpayer may deduct her MBA education as unreimbursed business expense (no more than 25 words).

1. IRC section 6672 contains one of the most severe penalties set forth in the Internal Revenue Code. The penalty serves as a major deterrent for taxpayers that fail to comply with their duty to withhold and submit payroll-related taxes. What is the penalty percentage on the amount of tax evaded under section 6672?

1. Read the supplemental material about primary/secondary sources of tax research and 2-15 through 2-17 in the textbook. What is the relative authoritative weight for IRS letter rulings, Revenue Procedures and Treasury Regulations?

Last year your client, the Rattameyers, were featured on Surprise Home Makeover, a network television show in which families are chosen to receive a ?home makeover? by a team of designers, paid for by the producers of the show. The show sent the family to the DisneyWorld Resort in Orlando, Florida for one week, while its team of designers, carpenters, and other construction professionals ripped out substantial portions of their home and made extravagant renovations for its television audience. The Rattameyers entered into a contract with the producers of Surprise Home Makeover in which they rented their home to the producers for one week, in return for $50,000 rent, and an all-expenses paid trip to Disney World for the entire family. The estimated value of the Disney World vacation was $15,000. While the family was away, Surprise Home Makeover?s team of designers essentially gutted the interior of their home, and rebuilt it. All considered, the show spent approximately $250,000 renovating and remodeling the Rattameyers? home. The producers assured the Rattameyers that the rent they received is nontaxable since the rental period was for less than 15 days. They also assured them that the value of the improvements would not be taxable until they sell the house, because the improvements were made by the producers as tenants.

Now the Rattameyers have come to your office for preparing their federal income tax return and on whether they should rely on the producer?s word in terms of their gross income of last year that may or may not be subject to federal income tax.

You would like to help the Rattameyers in minimizing their taxable income. However, based on your experience, you also know that the Internal Revenue Service may not agree with the position that the rent and the improvements on the house that the Rattamyers received are non-taxable. The Service may assert that the producers were not renting the home to live in it, but to use it as a backdrop, or studio, to film one week?s episode of the show. The IRS may argue that the Rattameyers understated their taxable income last year by $315,000, the value of the vacation, the cash rent and the value of the home renovations transferred to them by the producers of Surprise Home Makeover. The Service?s contention may be that the family received this payment in exchange for their agreement to be on the show as compensation.

For the Rattameyers, you have researched the relative issues in the RIA Checkpoint database. After determining the major IRC code sections (what are they?) for this case, you also came across a document named Private Letter Ruling 8104117 issued by the Internal Revenue Service.

Your Task:

Please decide what you would recommend to the Rattamyers about their income from the TV producer. Be specific on each item (the rent, the Disneyland vacation, and the renovation/remodeling). In making your recommendations, you need to explain to them:

a) What are the reasons for your decision? Is your decision based on substantial authority?

b) If you decide that the items are not included in gross income, what is the legal doctrine that may disallow your position by the courts? Can the taxpayer use the above-mentioned private letter ruling in court if litigation with the IRS arises?

I will need the following items to grade this assignment:

To answer the case study questions, please type your answer with a word processor and hand in a hard copy.

AND

Write down your answers to the research question 1-7 on page 1.

Acc380 Tax Research Assigned Reading Primary and Secondary Authority Primary Authority o Can be cited before the IRS or a Court o Is generally produced by a governmental entity or agency o However, not all authority produced by a governmental entity or agency is primary authority Secondary Authority o Includes any tax-related content that is not primary authority o Cannot be cited before the IRS or a Court o Includes everything from explanations written by third- party content developers (e.g., CCH IntelliConnect & RIA checkpoint) to articles posted on the Internet Use caution when referencing secondary authority; 3 Acc380 Tax Research Assigned Reading Primary Authority Internal Revenue Code The Internal Revenue Code of 1986 is generally the highest authority in tax matters. The Code can only be changed by an act of the U.S. Congress. The Code is found in Title 26 of the U.S. Code. It is organized into subtitles, chapters, subchapters, parts, and subparts. Within these Code divisions, you will find the provisions of the Code in sequentially numbered sections. You cite a Code provision by section number (denoted by the symbol \"\"). For example, 1 of the Code is titled \"Tax Imposed\" and it begins \"There is hereby imposed....\" Section 1 is found in Subtitle A, Chapter 1, Subchapter A, Part I, but we simply refer to it as \"1.\" Within each Code section, you may find subsections, paragraphs, subparagraphs, clauses, and subclauses. For example, 1(a) refers to subsection (a) of Code 1. U.S. Treasury Regulations The United States Treasury Department has the authority (under Code 7805) to \"prescribe all needful rules and regulations for the enforcement of this title [Title 26], including all rules and regulations as may be necessary ... in relation to internal revenue.\" Treasury regulations may be proposed, temporary, or final. Proposed regulations are released for public comment and are not authoritative, but they contain useful information regarding the IRS's position on a matter. Temporary regulations are released for public comment and have the authority of final regulations. Regulations follow the numerical sequencing of the related Code section. In a regulation citation, the Code section number is preceded by a number indicating the type of regulation (e.g., \"1\" is a general income tax regulation and \"301\" relates to administrative provisions). The Code section number is followed by a numerical sequence. For example, Reg. 1.1031(j)-1 is an income tax regulation, and it is the first (and happens to be the only) regulation related to Code 1031(j). This regulation relates to the likekind exchange of multiple properties. 4 Acc380 Tax Research Assigned Reading U.S. Court Opinions Tax proceedings can be brought forth in various \"courts of original jurisdiction,\" including U.S. District Courts, the U.S. Court of Federal Claims, or the U.S. Tax Court. Either the taxpayer or the IRS may appeal a decision from any of the above courts. An appeal from District Court or the Tax Court is to the Court of Appeals in the taxpayer's jurisdiction. An appeal from the Court of Federal Claims is to the U.S. Court of Appeals for the Federal Circuit. An appeal from any of the appellate courts is to the U.S. Supreme Court, which may or may not agree to hear the case. A Supreme Court decision may provide additional guidance regarding implementation of a given Code section or it could invalidate a Code provision as being unconstitutional. A citation to a court case takes the form: Plaintiff v. Defendant, Publication (Volume, Name, Page), Court, Date. For example, consider the citation \"Mayo v. United States, 2011-1 U.S.T.C. 50,143, (Jan. 11, 2011).\" Mayo and the U.S. are the plaintiff and defendant in the case. 2011-1 is the volume number in the U.S.T.C. (U.S. Tax Cases) series, and 50,143 is the page (in this case paragraph) reference. Because this is a Supreme Court case, the court name is implied, rather than stated. The date of the ruling is shown. IRS Rulings The IRS issues various types of rulings that are considered primary authority, including Revenue Procedures (Rev. Procs.) and Revenue Rulings (Rev. Ruls.). Revenue Procedures provide IRS guidance on administrative matters. For example, Rev. Proc. 2012-1 outlines procedures for requesting certain rulings from the IRS. Revenue Rulings offer guidance to taxpayers related to the IRS's position on how a Code provision should be interpreted in a specific factual circumstance. For example, Rev. Proc. 2000-50 provides guidance regarding treatment of computer software costs. 5 Acc380 Tax Research Assigned Reading Secondary Authority. In a tax research situation, you may refer to secondary authority for a broad discussion of your topic. This is especially valuable if your topic relates to two or more Code sections. The features of secondary authority are: Secondary authority includes any tax-related resource that is not classified as primary authority. Secondary authority cannot be cited before the IRS or a Court. Secondary authority includes RIA explanations and other resources available under "Editorial Materials". Secondary authority also includes articles posted on the Internet, such as Wikipedia postings or articles posted on the web sites of various accounting or law firms. Use extreme caution when reviewing tax articles on such web sites. Secondary authority can be helpful in providing a general and easily understood discussion of a topic. However, you should take care to review the related primary authority to make sure the secondary authority 1) is accurate, and 2) relates to your specific situation. 6 Tax research assignment. Due Wednesday 3/9 Name: Class meeting time: 1. Which specific part of the Internal Revenue Code defines \"qualifying relative\"? 2. Which Internal Revenue Code Section spells out the tax treatment for landlords (lessor) when they have improvements made by their tenants (lessee) on their rental properties? 3. We know from Chapter 6 that rental expenses are FOR AGI deductions. Find a Tax Court & Board of Tax Appeals reported decision in RIA Checkpoint that is about the deduction of the rental expenses of vacation home in 1981. _______ v. ________ _____ TC ______ 4. Where is \"capital asset\" defined in the code? 5. Find the case named \"Singleton-Clarke v. Commissioner\". Summarize the reason why the taxpayer may deduct her MBA education as unreimbursed business expense (no more than 25 words). 6. IRC section 6672 contains one of the most severe penalties set forth in the Internal Revenue Code. The penalty serves as a major deterrent for taxpayers that fail to comply with their duty to withhold and submit payroll-related taxes. What is the penalty percentage on the amount of tax evaded under section 6672? 7. Read the supplemental material about primary/secondary sources of tax research and 2-15 through 2-17 in the textbook. What is the relative authoritative weight for IRS letter rulings, Revenue Procedures and Treasury Regulations? 1 Tax research assignment. Due Wednesday 3/9 Name: Class meeting time: Last year your client, the Rattameyers, were featured on Surprise Home Makeover, a network television show in which families are chosen to receive a \"home makeover\" by a team of designers, paid for by the producers of the show. The show sent the family to the DisneyWorld Resort in Orlando, Florida for one week, while its team of designers, carpenters, and other construction professionals ripped out substantial portions of their home and made extravagant renovations for its television audience. The Rattameyers entered into a contract with the producers of Surprise Home Makeover in which they rented their home to the producers for one week, in return for $50,000 rent, and an allexpenses paid trip to Disney World for the entire family. The estimated value of the Disney World vacation was $15,000. While the family was away, Surprise Home Makeover's team of designers essentially gutted the interior of their home, and rebuilt it. All considered, the show spent approximately $250,000 renovating and remodeling the Rattameyers' home. The producers assured the Rattameyers that the rent they received is nontaxable since the rental period was for less than 15 days. They also assured them that the value of the improvements would not be taxable until they sell the house, because the improvements were made by the producers as tenants. Now the Rattameyers have come to your office for preparing their federal income tax return and on whether they should rely on the producer's word in terms of their gross income of last year that may or may not be subject to federal income tax. You would like to help the Rattameyers in minimizing their taxable income. However, based on your experience, you also know that the Internal Revenue Service may not agree with the position that the rent and the improvements on the house that the Rattamyers received are non-taxable. The Service may assert that the producers were not renting the home to live in it, but to use it as a backdrop, or studio, to film one week's episode of the show. The IRS may argue that the Rattameyers understated their taxable income last year by $315,000, the value of the vacation, the cash rent and the value of the home renovations transferred to them by the producers of Surprise Home Makeover. The Service's contention may be that the family received this payment in exchange for their agreement to be on the show as compensation. For the Rattameyers, you have researched the relative issues in the RIA Checkpoint database. After determining the major IRC code sections (what are they?) for this case, you also came across a document named Private Letter Ruling 8104117 issued by the Internal Revenue Service. Your Task: Please decide what you would recommend to the Rattamyers about their income from the TV producer. Be specific on each item (the rent, the Disneyland vacation, and the renovation/remodeling). In making your recommendations, you need to explain to them: 2 Tax research assignment. Due Wednesday 3/9 Name: Class meeting time: a) What are the reasons for your decision? Is your decision based on substantial authority? b) If you decide that the items are not included in gross income, what is the legal doctrine that may disallow your position by the courts? Can the taxpayer use the abovementioned private letter ruling in court if litigation with the IRS arises? I will need the following items to grade this assignment: To answer the case study questions, please type your answer with a word processor and hand in a hard copy. AND Write down your answers to the research question 1-7 on page 1. 3