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Project #1 – The Treasure Hunt An Individual Project Covering Chapters 1 thru 3 Legislative, Administrative & Judicial Sources of Tax Authority Using RIA or CCH – Locate Pollock v
Project #1 – The Treasure Hunt
An Individual Project Covering Chapters 1 thru 3
Legislative, Administrative & Judicial Sources of Tax Authority
- Using RIA or CCH – Locate Pollock v. Farmers’ Loan & Trust Company.
Required items –
-
- Copy 1st page of Court’s opinion;
- Give full citation for this case;
- This is an example of what source of tax authority? &
- Who wrote the majority opinion?
- Find the Notice that provides for the optional mileage rate for 2020 for the business use of an automobile. Required items –
- Copy 1st page of the Notice;
- Provide a proper citation for the Notice;
- This is an example of what source of tax authority?
- What is the standard mileage rate for business use of an auto?
- Does notice provide for other standard mileage rates? &
- If so, give an example.
- Winter Nationals are coming to Pomona Fair Grounds. Peter Clifford, CEO, needs to know – “Is racing fuel with 110 octane subject to the gasoline excise tax?” Required items –
- Copy page 1 of Private Letter Ruling (i.e. PLR);
- Provide proper citation for the PLR and indicate its holding; &
- Advise Peter about its holding – one or two sentences.
- Locate a tax case involving a producer & promoter of the musical group New Kids on the Block. Required items –
- Provide the case name and citation for case.
- Now look up a real musical group the Eagles – locate a tax case involving the ex-wife of a member of the Eagles musical group regarding who should pay tax on royalty income. Hint the original members of the Eagles were Don Henley, Bernie Leadon, Randy Meisner & Glenn Frey. Required items-
- Provide the case name and citation for case.
- Locate a tax case involving tax deduction for a business selling medical marijuana. Required items-
- Provide the case name and citation for case.
- Determine whether each of the following IRS Rulings is a Field Service Advice. Private Letter Ruling, Service Center Advice or Technical Memorandum:
|
Item |
Citation |
Type of IRS Ruling |
|
A |
201214021 |
|
|
B |
200235031 |
|
|
C |
200051044 |
|
|
D |
201620016 |
|
|
E |
201303008 |
|
- Identify the circuit court of appeals for taxpayers living in each of the following states:
|
Item |
State |
Circuit Court of Appeals |
|
A |
Florida |
|
|
B |
New York |
|
|
C |
Arizona |
|
|
D |
California |
|
|
E |
Michigan |
|
|
F |
Wyoming |
|
|
G |
Nebraska |
|
- Rank the following items from the lowest to highest authority in the Federal tax law system:
|
Item |
Description |
Ranking (i.e. 1st, 2nd, etc.) |
|
A |
Interpretive Regulation |
|
|
B |
Legislative Regulation |
|
|
C |
Letter ruling |
|
|
D |
Revenue Ruling |
|
|
E |
Internal Revenue Code |
|
|
F |
Proposed Regulation |
|
- Referring to the citation only, determine which court issued these decisions:
|
Item |
Citation |
Name of Court that issued Decision |
|
A |
716 F 2d 693 (CA-9, 1983) |
|
|
B |
20 TC 734 (1953) |
|
|
C |
348 US 426 (1955) |
|
|
D |
3 BTA 1042 (1926) |
|
|
E |
TC Memo 1957-169 |
|
|
F |
50 AFTR2d 92-6000 (Ct Cl, 1992) |
|
|
G |
Letter Ruling 9046036 |
|
|
H |
111 F Supp 2d 1294 (S.D.N.Y.,2000) |
|
|
I |
98-50, 1998-1 CB 10 |
|
- Using the legend provided, classify each of the following tax sources:
Legend
P = Primary Tax Source
S = Secondary Tax Source
B = Both
N = Neither
|
Item |
Tax Source |
Type of Tax Source |
|
A |
Sixteenth Amendment of the US Constitution |
|
|
B |
Tax Treaty between United States & India |
|
|
C |
Revenue Procedure |
|
|
D |
An IRS publication |
|
|
E |
US District Court decision |
|
|
F |
Yale Law Journal article |
|
|
G |
Temporary Regulations (issued 2019) |
|
|
H |
US Tax Court Memorandum decision |
|
|
I |
Small Cases Division of the US Tax Court decision |
|
|
J |
House Ways and Means Committee report |
|
|
K |
Notice |
|
- Using either CCH or RIA locate Internal Revenue Code Sections 162 & 212.
Required items –
-
- Copy the 1st page of each Code section;
- Give a brief description of the type(s) of expenses that covered by each code section; &
- What is the key phrase used in each of these code sections involving expenses?
- Using either CCH or RIA locate Internal Revenue Code Section 199A.
Required items –
-
- Copy the 1st page of this Code section; &
- What is the definition of a qualified trade or business?
- Using either CCH or RIA locate Internal Revenue Code Sections 276.
Required items –
-
- Copy the 1st page of this Code section;
- What types of expenses are covered by IRC §276?
- Go to the IRS website and find the title for the following IRS Publications:
|
Item |
IRS Publication |
Title to IRS Publication |
|
A |
Publication 5 |
|
|
B |
Publication 463 |
|
|
C |
Publication 936 |
|
- For Regulation §1.163-10(a)(2):
|
Item |
Question |
Answer |
|
A |
What does the “1” represent? |
|
|
B |
What does the “163” represent? |
|
|
C |
What does the “10” represent? |
|
|
D |
What does the “(a)” represent? |
|
|
E |
What does the “(2)” represent? |
|
Just a little more –
- Locate the Regulation listed above and print 1st page of this Regulation;
- What is the title of the Regulation? &
- What is the heading of the actual portion of the Regulation cited above?
- How many regulations have been issued for the following Code Sections?
|
Item |
IRS Publication |
Title to IRS Publication |
|
A |
IRC §212 |
|
|
B |
IRC §197 |
|
|
C |
IRC §1502 |
|
- Using RIA or CCH, locate the Internal Revenue Code section dealing with the deductibility of medical expenses for individual taxpayers. Required items –
- What is the number for this Internal Revenue code section?
- Are medical expenses deductible in the year incurred or in the year paid? Required –
- Find a Regulation which determines when medical expenses are deductible and give citation of this regulation.
- Find a Revenue Ruling which pertains to eye surgery for defective vision such as LASIK and radial keratotomy. Required –
- Give a citation for this revenue ruling.
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