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What is the difference between open and closed facts? How is this distinction important in conducting tax research? Describe the differences between the three types

What is the difference between open and closed facts? How is this distinction important in conducting tax research?

Describe the differences between the three types of audits in terms of their scope and taxpayer type.

Benita is concerned that she will not be able to complete her tax return by April 15. Can she request an extension to file her return? By what date must she do so? Assuming she requests an extension, what is the latest date that she could file her return this year without penalty?

What are the five basic parts of an internal research memo?

Mason was shocked to learn that the current Code is the Internal Revenue Code of 1986. He thought that U.S. tax laws change more frequently. What is wrong with Mason's perception?

Compare and contrast the three types of tax law sources and give examples of each.

What is the difference between primary and secondary authorities? Explain the role of each authority type in conducting tax research.

What is Circular 230?

Describe in general the process by which new tax legislation is enacted.

Explain how implicit taxes may limit the benefits of the conversion strategy.

The concept of the time value of money suggests that $1 today is not equal to $1 in the future. Explain why this is true.

What is the constructive receipt doctrine? What types of taxpayers does this doctrine generally affect? For what tax planning strategy is the constructive receipt doctrine a potential limitation?

What are the two basic timing strategies? What is the intent of each?

Explain why paying dividends is not an effective way to shift income from a corporation to its owners.

Relative to arm's-length transactions, why do related-party transactions receive more IRS scrutiny?

What factors increase the benefits of accelerating deductions or deferring income?

Name three common types of income shifting.

What is an "implicit tax" and how does it affect a taxpayer's decision to purchase municipal bonds?

Explain how implicit taxes may limit the benefits of the conversion strategy.

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