Internal Revenue Case Study

Parent Corporation owns 85% of the common stock and 100% of the preferred stock of Subsidiary Corporation. The common stock and preferred stock have adjusted bases of $500,000 and $200,000, respectively, to Parent. Subsidiary adopts a plan of liquidation on July 3 of the current year, when its assets have a $1 million FMV. Liabilities on that date amount to $850,000. On November 9, Subsidiary pays off its creditors and distributes $150,000 to Parent with respect to its preferred stock. No cash remain to be aid to Parent with respect to the remaining $50,000 of its liquidation preference for the preferred stock, or with respect to any common stock. In each of Subsidiary’s tax years, less than %10 of its gross

Billy’s Beats Inc., an SEC registrant, is a new audit client with a fiscal year-end of December 31, 2010. Billy’s is a manufacturer of musical instruments. Billy’s acquired Little Drummer Boy Inc. in 2010 for $575 million in cash. Significant assets acquired included property, plant, and equipment totaling $865 million and other assets totaling $145 million. The useful lives assigned to the property, plant, and equipment acquired were 30 years for the plant and 15 years for the equipment. The useful lives for the plant and equipment already owned by Billy’s are 20 years and 10 years. Other included assets of acquired customer lists, were

Therefore, each partners’ distributive shares of income attributable to the transfer of all substantial rights to the patent would be considered proceeds from the sale or exchange of a capital asset held for more than 1 year.

was later found by the buyers to contain more than $30,000 in cash, how did the court

dealt at arm’s length, and the selling price of $1,250,000 is the fair market value of the shares at the

ABC Corporation ends its tax year on October 30. When must ABC’s income tax return be filed for the year ending October 30, Year 1?

As demonstrated below, the petitioner had the ability to pay the proffered wage to the beneficiary in 2004 and 2005, even if its ordinary business income for those years was lower than the proffered wage.

My clients, Charlene and Alton Dutro, have lived in their home for two and one-half years. However, the Dutros choose to remodel and enlarge their house. Consequently, their architect cautioned that increasingly strict building and permit restrictions had been in effect since a decade ago when the house was built. As a result, the Dutros decided to demolish their house and rebuild on the property. They did not reside in the house but instead sold it and realized a gain of over $500,000. For calculation on their Federal income tax return, the Dutros reduced the realized gain that exceeded the $500,000 by the $500,000 exclusion of § 121. The IRS issued an income tax deficiency notice because they noted that the Dutros did not satisfy the two-out-of-five years requirement under § 121 (a). Consequently, the present issue is to determine who is correct in this situation. Therefore, I must ascertain if the Dutros satisfied this requirement under § 121 (a).

Caitlin and Wally formed the C&W Partnership on September 20, 2012. Caitlin contributed cash of $195,000, and Wally contributed office furniture with a FMV of $66,000. He bought the furniture for $60,000 on January 5, 2012, and placed it in service on that date. Wally will not elect Sec. 179 expensing on the furniture and elected out of bonus depreciation. He also contributed and office building and land with a combined FMV of $129,000. The land’s FMV is $9,000. Wally bought the land in 2005 for $8,000 and had the building constructed for $100,000. The building was placed in service in June 2008.

Variable Interest Entities (VIEs) are addressed in ASC 810-10-15 with a subtopic addressing VIEs. ASC 810-15-17(d) states the criteria to be considered in determining if a VIE qualifies for the business scope exception [1]. These criteria are paraphrased in the latter of this analysis.

Facts: Murray Taxpayer was previously employed by a company who was illegally dumping chemicals into a river. Murray had knowledge concerning these illegal activities of his employer and made an ethical decision to report this to the Environmental Protection Agency. Upon inspection, the Environmental Protection Agency determined that Murrays employer was in fact illegally dumping and was appropriately fined for the charges. Murray’s employer reacted to his whistleblowing by firing him and making deliberate efforts to prevent Murray from gaining employment elsewhere. Murray then sued his former employer for damaging

The Stakeholders are individuals or groups, inside or outside of the organization, encouraging, directly or ramblingly of the success of the team (Palmer, Dunford, & Akin, 2009, p.146). Charles Rossotti took leadership at the Internal Revenue Service (IRS) in 1997 as commissioner to amid complaints of abuse of workers and taxpayers (Riccucci, Rainey, & Thompson, 2006, p.596). Rossotti supervised the establishments and the stakeholders of IRS. The primary stakeholders in the transformation of the IRS are the internal stakeholders meaning the employees such as the tax preparators. In additional the external stakeholders are the customers identified as the taxpayers. Rossotti’s determination was to show to the Congress that the employees and the

Due to the information, 20 acres of land equal 80 sheep according to the exchange rate of last year, a one-room cabin equal 3 acres of land and equal 12 sheep finally, a plow equals 2 goat and equal 2/3 sheep according to last year’s exchange rate and 2 carts which were traded with a poor acre of land equals 8 sheep plus 400 sheep. So Deyonne’s total assets are 500(2/3) sheep. Deyonne’s liabilities and assets deduction are 35 sheep plus 3 sheep, which will come to 38 sheep,

KPMG was one of the biggest accounting firms in the 90’s that with a lucrative end, would serve wealthy companies using forged revenues in order to avoid taxes. The accountants that worked for the firm were expected to meet certain quotas. Consequently, instead of trying to run an honest business they were trying to maximize the sales using all kinds of dishonest marketing approaches. KPMG employees used foreign banks as well as bogus law firm statements to preserve a legitimate business running. This accounting firm manipulated financial data of clients, costing the internal revenue service over 2.5 billion in lost tax revenue

Though it may not be open to a State legislature to make provision for the recovery of an amount which is not a tax under Entry 54 of List II in a law made for that purpose, it would still be open to the legislature to provide for paying over all the amounts collected by way of tax by persons, even though they really are not exigible as tax, as part of the incidental and