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Homework answers / question archive / 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

Taxation

Project #1 – The Treasure Hunt

An Individual Project Covering Chapters 1 thru 3

Legislative, Administrative & Judicial Sources of Tax Authority

  1. Using RIA or CCH – Locate Pollock v. Farmers’ Loan & Trust Company.

Required items –

    1. Copy 1st page of Court’s opinion;
    2. Give full citation for this case;
    3. This is an example of what source of tax authority? &
    4. Who wrote the majority opinion?

 

 

  1. Find the Notice that provides for the optional mileage rate for 2020 for the business use of an automobile. Required items –
    1. Copy 1st page of the Notice;
    2. Provide a proper citation for the Notice;
    3. This is an example of what source of tax authority?
    4. What is the standard mileage rate for business use of an auto?
    5. Does notice provide for other standard mileage rates? &
    6. If so, give an example.

 

 

  1. 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 –
    1. Copy page 1 of Private Letter Ruling (i.e. PLR);
    2. Provide proper citation for the PLR and indicate its holding; &
    3. Advise Peter about its holding – one or two sentences.

 

 

  1. Locate a tax case involving a producer & promoter of the musical group New Kids on the Block. Required items –
    1. Provide the case name and citation for case.

 

 

  1. 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-
    1. Provide the case name and citation for case.

 

 

  1. Locate a tax case involving tax deduction for a business selling medical marijuana. Required items-
    1. Provide the case name and citation for case.
  2. 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

 

 

 

  1. 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

 

 

 

  1. 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

 

 

  1. 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

 

 

  1. 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

 

 

 

  1. Using either CCH or RIA locate Internal Revenue Code Sections 162 & 212.

Required items –

    1. Copy the 1st page of each Code section;
    2. Give a brief description of the type(s) of expenses that covered by each code section; &
    3. What is the key phrase used in each of these code sections involving expenses?

 

 

  1. Using either CCH or RIA locate Internal Revenue Code Section 199A.

Required items –

    1. Copy the 1st page of this Code section; &
    2. What is the definition of a qualified trade or business?

 

 

  1. Using either CCH or RIA locate Internal Revenue Code Sections 276.

Required items –

    1. Copy the 1st page of this Code section;
    2. What types of expenses are covered by IRC §276?
  1. 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

 

 

 

 

  1. 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 –

  1. Locate the Regulation listed above and print 1st page of this Regulation;
  2. What is the title of the Regulation? &
  3. What is the heading of the actual portion of the Regulation cited above?

 

 

  1. 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

 

 

 

 

  1. Using RIA or CCH, locate the Internal Revenue Code section dealing with the deductibility of medical expenses for individual taxpayers. Required items –
    1. What is the number for this Internal Revenue code section?

 

 

  1. Are medical expenses deductible in the year incurred or in the year paid? Required –
    1. Find a Regulation which determines when medical expenses are deductible and give citation of this regulation.

 

 

  1. Find a Revenue Ruling which pertains to eye surgery for defective vision such as LASIK and radial keratotomy. Required –
    1. Give a citation for this revenue ruling.

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