237 Individual Income Taxes
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.
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
memoramdum is to be no more than one page in length.
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.
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)
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
has secured your power of attoney to represent him with IRS.