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TAX RESEARCH PROBLEMS 1:15-63 The purpose of this problem is to enhance your skills in interpreting the authorities that you locate in your research. In

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TAX RESEARCH PROBLEMS 1:15-63 The purpose of this problem is to enhance your skills in interpreting the authorities that you locate in your research. In answering the questions that follow, refer only to Thomas A. Curtis, M.D., Inc., 1994 RIA TC Memo 494,015 (T.C. Memo 1994-15), 67 TCM 1958. a. What was the principal controversy litigated in this case? b. Which party-the taxpayer or the IRS-won? c. Why is the corporation instead of Dr. and/or Ms. Curtis listed as the plaintiff? d. What is the relationship between Ellen Barnert Curtis and Dr. Thomas A. Curtis? e. Approximately how many hours a week did Ms. Curtis work, and what were her credentials? f. For the fiscal year ending in 1989, what salary did the corporation pay Ms. Curtis? What amount did the court decide was reasonable? What dividends did the corporation pay for its fiscal years ending in 1988 and 1989? h. To which circuit would this decision be appealable? i. According to Curtis, what five factors did the Ninth Circuit mention in Elliotts, Inc. as relevant in determining reasonable compensation? -16 CATech contribute S5 000 tund ehe erinn Li

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