Question
Research and turn in your documentation and responses to G-12 and G-17 on page 483 of your Tax Research text, then turn in via the
Research and turn in your documentation and responses to G-12 and G-17 on page 483 of your Tax Research text, then turn in via the hand-in assignment. Be sure that you type the chapter number and the question number on each one of your cases.
You will use Checkpoint not CCH AnswerConnect to do your research!
We do not subscribe to the CCH service. Like every chapter since chapter 5, most of these cannot be answered by looking in the code section or regulations. I believe that you will have to find one of the court cases described in chapter 5 to answer your cases.
You will probably need:
- the code section(s) (with highlighted material that is relevant to your case)
- administrative source(s) (like a regulation with highlighted material that is relevant to your case)
- a judicial or legislative source(s) like a case from one of the courts (with highlighted material that is relevant to your case)
- a citation run on your administrative or judicial source (since we don't have access to CCH Citator yet, you may skip this step for your cases; however, it is an important step when doing real-world tax research, so I am not omitting it from your instructions)
- and an answer that references the code section, an administrative ruling, and a court case to justify your answer
You may not have to have an administrative and judicial source for some of these cases, but there are cases that will require all three types of primary sources. Be aware that if your reference starts with the paragraph symbol (), it is a secondary source, not a primary source. You need to use the IRC for your primary source -- DO NOT USE CFR or e-CFR. Grammatical errors cause point deductions. Do not forget to label your case with a chapter number and case number.
Here is the question.
G-17.Frank and Sharon have been married for five years and have filed joint tax returns during this period. Without Franks knowledge, Sharon has been operating an escort service from the local pub. This years operations were very profitable. In fact, if Sharon had reported the net escort income, their joint federal income tax liability would have increased by $50,000. When Sharon finally is nabbed by the police, she is taken to jail. Frank is unable to locate any of Sharons earnings in their personal bank or brokerage accounts. Can Frank fend off the IRSs charge that he should pay the $50,000 in tax, plus interest and penalties, from his salary as an engineer?
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