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Individual Income Taxes Research Paper

Question # 00185825
Subject: Law
Due on: 02/06/2016
Posted On: 02/01/2016 09:48 PM

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Accounting 237 Individual Income Taxes

The attached research case should be prepared by using RIA checkpoint online tax research database. Be sure you provide enough citations (the applicable Law) to support your analysis and conclusion.

Assume you have a tax practice. You are advise your client as his best courses of action or approach. Remember that you are representing your client as his advocate. Prepare a tax file memorandum with the facts, tax issues, law citations, analysis, and your conclusions. (See Page A- of the PH Tax Research Working Paper File handout attached.)

The memoramdum is to be no more than one page in length.

Hades died on April 13, 2006. The executor of his estate made the 2032 (a) election to use the alternate valuation date in filing Hades' estate tax return. With the primary valuation date and amount, the estate assets would have been valued at $3.5 million. With this election, the estate assets were valued at $ 3.0 million.

A major asset of the estate was shares of SOB Corporation. Those shares were traded on an established securities market. Because the estate owned 2% of SOB's stock, the executor secured the services of a major brokerage firm to calculate the blockage discount on the stock. Shortly, before the estate tax return due date of January 13, 2007, the executor filed Form 4768 (Extension Request for Estate Tax Return) requesting an execution for filing until July 13, 2007, and paid $400,000 in estimated taxes with the request. In early June, the brokerage firm notified the executor that it would not be able to finish the valuation on time. Another firm was engaged, and it completed the valuation on November 29, 2007. Hades' executor finally filed the estate return on January 19, 2008 and made the 2032 (a) election.

IRS determined that a 2032 (a) election cannot be made unless the estate tax return was filed on a timely basis. A deficiency was assessed based on the asset valuation of $3.5 million rather than $3.0 million.

Hades has secured your power of attoney to represent him with IRS.

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individual income tax research

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Posted On: 02/06/2016 12:02 PM
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Tutorial Preview …return xxx date xx January 13, xxxxx the executor xxxxx Form xxxx xxxxxxxxxx…
Individual_Income_Taxes_Research_Paper.doc (45.5 KB)
Preview: a xxxx to xxx extent that xxx transfer amount xxxxxxx the xxxxxxxxxxx xxxxx in xxx property The xxxxxxxxxxx transferred a xxx third xxxxxxxx xx the xxxxxxx providing partner, xxxxx gave him x 66,000 xxxxx xx the xxxxxxxxxxx The interest xxxx was transferred xx the xxxxxxx xxxxxxxxx partner xxxx not exceed xxx partnerships basis xx the xxxxxxxx xxxxx I x C 83(h) xxx partnership is xxxxxxx to xxxxxx xxx interest xx the partnership xxxx was transferred xx the xxxxxxx xxxxxxxxx partner xxxxxxxx v Commissioner, xx T C xxx (1974) xxxxxx xxx issues xxxxxxxxx the formation xx a joint xxxxxxx and xxxx xxxxxxxxxxx We xxxx distinguish from xxxxxxxx for many xxxxxxx First, xxxxxxxx x Commissioner xxxxxxxx a joint xxxxxxxx not a xxxxxxxxxxx Secondly, xxxxxxxx xxxx place xxxxxxx of our xxxxxxxx where there xxx be xxxx xxxxxxxxxxx in xxx tax liability xxxxxx are resolved xxxxxxxxx to xxxxxxxx xxxxxxxxxx courts xxxx are located xx different districts xxx have xxxxxxxxx xxxxxxxx on xxx some tax xxxxxxxxx issues should xx resolved xx xx not xxx responsibility of xxx court to xxxxxx the xxxxxx xx another xxxxx in a xxxxxxxxx district, but xxx a xxxxx xxx following xxx rulings of xxx District Court xx Appeals xx xxx Supreme xxxxx Thirdly, there xxx no other xxxxx cases xxxxxxxxx xxxxxxxx which xxxx reaffirmed the xxxxxxxx of the xxxxx There xxxx xxxx references xxxx to McDougal xx varying degrees, xxx there.....
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