Writing Project for Acct. 757 Prof. Scott Ahroni This assignment should help you practice putting tax ideas and specific content into a clear, professional written format. Styles for such memoranda can vary according to the context and purpose of the project. For purposes of this project, you are to assume that you are a first year accountant at an accounting firm and your supervisor or manager/partner asked you to write a memo on an appropriate tax topic to refresh his or her understanding of the issues involved. You are to write a research paper that develops and explains in a clear, coherent manner, the following issues. Your memorandum should contain specific references to appropriate Internal Revenue Code provisions and Regulation sections, any rulings or cases that are relevant, and any other citations. You may use any source to accomplish this including other materials on the QC Library's database, other textbooks or articles, etc. You must, however, give proper credit in footnotes for any source you quote or paraphrase. The citation should be clear. If it is a case, give the main name and citation found in Checkpoint. If possible, the paper should include a reference to some relatively recent development such as a new ruling or case on your topic. You can use the Citator to check for sources that refer to a source you already have. You can also search Checkpoint databases including a key word search. Issues to Be Discussed: Your client, Edward Bolleni, CPA has recently left his Big Four position and is out on his own. After preparing tax returns for the 2019 tax year, Mr. Bolleni has decided to operate his own accounting firm. Mr. Bolleni wants limited liability protection in his operations as an accountant, as well as, liability protection from any accidents or slip and falls that would occur in his accounting office. Mr. Bolleni has an accounts receivable worth $50,000 for tax preparation fees for the 2019 tax year, as well as, an interest in a real estate partnership that is used as collateral for a loan that Mr. Bolleni received from Bank of America so that he could have additional capital for his new business. The fair market value of the real estate partnership interest is $500,000 and the loan is for $200,000. Mr. Bolleni comes to your office and asks you the following questions: A. What type of entity, if any, did Mr. Bolleni operate in 2019? If you believe that Mr. Bolleni operated an entity in 2019, what tax forms does Mr. Bolleni have to file to report the entity's income, gains, losses, deductions and credits? B. Which type of legal entity would be best suited to provide the type of limited liability protection the taxpayer is seeking? C. Whether, for tax purposes, Mr. Bolleni can contribute his assets to either a corporation or partnership tax-free? If so, explain your answer. If not, explain your answer. D. If the taxpayer does contribute the assets to the corporation, the taxpayer wants to know what tax impact if any, would happen if he immediately transferred 50% of the shares in the corporation to his wife as a gift. E. If your answer to (D) above would be different if the taxpayer's wife contributed services to the corporation in return for her 50% shareholder interest. F. Whether and to what extent Mr. Bolleni can claim the 199A deduction against the income from his newly created entity
