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The loan is a bona fide loan. Smith: This letter is in response to your request concerning the minimum amount of estimated tax you must pay for so that you will not have to pay any additional tax upon filing your Federal income tax return. This estimate is based on the following computation.
Sincerely yours, John J. Jones, CPA Partner. She wanted to know the minimum amount of estimated tax she would have to pay for the calendar year so that she would not have to pay any additional tax upon filing her Federal income tax return.
Items remaining unchanged from Salary Christmas bonus Itemized deductions Interest income Alimony Office rent expense. No bad debt deduction on uncollected rents can be taken because Mason and Ruth are cash basis taxpayers. Rent collected from prior year must be included in gross income because Mason and Ruth are cash basis taxpayers.
This fact pattern is similar to Clifford L. Brody and Barbara J. De Clerk, T. Summary Opinion, — The record indicated that the loan was a personal loan between the bank and petitioners and not a loan from petitioners to the corporation.
In addition, it appeared likely that the corporation was capable of eventually paying its alleged share of the debt if necessary. The fact pattern in this situation is similar to the fact pattern in Mark D. Ambrose and Jennifer L.
Ambrose v. The key is to determine in which year the casualty was sustained. Thus, we look to case law for additional guidance. In Oregon Mesabi Corp. However, the timber was rendered worthless when attacked by insects and fungi in and The court determined that a loss deduction was not necessarily taken in the year of the fire, but in the years, as shown by the evidence, that worthlessness occurred.
Despite the fact that the trees were weakened by the hurricane, they were not worthless until they died of disease. Research Problems 4 and 5 The Internet Activity research problems require that students utilize online resources to research and answer the questions.
As a result, solutions may vary among students and courses. You should determine the skill and experience levels of the students before assigning these problems, coaching where necessary. Encourage students to explore all parts of the Web in this research process, including tax research databases, as well as the websites of the IRS, newspapers, magazines, businesses, tax professionals, other government agencies, and political outlets. Students should also work with resources such as blogs, Twitter feeds, and other interest-oriented technologies to research their answers.
In the year of partial worthlessness. Mary should sell half each year. See Rev. While this argument met some initial success see, for example, Kentucky Utilities Co. Glenn, F. Tax Court and then by various appellate decisions affirming the decisions of that tax tribunal. See Miller v. CCH ; Hills v. Where the taxpayer has the right to receive insurance proceeds that would compensate for the loss, the loss suffered by the taxpayer is not damage to property caused by the casualty.
The committee believes that losses resulting from a personal decision of the taxpayer should not be deductible as a casualty loss. Under the bill, a taxpayer is not permitted to deduct a casualty loss for damages to property. Updated references and citations throughout the chapter. Updated materials on administrative tax law sources and commercial tax services. The discussion in Section of the chapter takes the student through the answer to the research questions posed.
Depending on the research services available, the instructor might ask the students to formulate keyword searches and then demonstrate what happens when those searches are undertaken in the research service. The instructor could also demonstrate the index feature of the research services to look up topics related to dependents or dependency exemptions. Alternatively, the instructor could ask the students to see if they could verify the correctness of the textbook conclusion or change one of the key facts e.
May not be scanned, copied or duplicated, or posted to a publicly accessible website, in whole or in part. The source of the Federal taxing authority is the U. Sixteenth Amendment. Internal Revenue Code. The Code generally is supreme in the Federal tax area, unless a U.
In this case, TAMRA of provides that neither a tax law nor a tax treaty takes general precedence. Instead, the most recent item will take precedence. Role of Congress. Unless a constitutional issue is involved, Congress can override a U. Supreme Court decision by amending the Code. Code supremacy. This Court supremacy is not the case when the Internal Revenue Code is concerned i. Congressional Committee Reports.
Congressional Committee Reports may be helpful in interpreting the Code. Congressional intent. Such reports reflect the intent of Congress in implementing or changing the tax law.
Cumulative Bulletins. Public and closed congressional hearings. Congress holds both public and closed hearings on tax proposals. After public hearings before the House Ways and Means Committee, the public may be excluded in a closed session.
Tax bills may be debated under a closed rule before the full House with approval by the Rules Committee. Under this closed rule, amendments are not allowed on the House floor unless approved by the House Ways and Means Committee.
Organization of the Code. The Code is organized into Subtitles, Chapters, and Subchapters. See Figure in these Lecture Notes. Interrelation of Code provisions. Tying the various Code provisions together to reach the total result is important. Code section numbers. Section numbers do not repeat in the same title of the Code. Some Code section numbers contain a capital letter e. Internal Revenue Code of Although Congress did not codify and rearrange the law in the Tax Reform Act of , the radical changes did provide some rationale for renaming the entire tax law in the Internal Revenue Code of General explanation of the act.
Upon the completion of major tax legislation, the staff of the Joint Committee on Taxation in consultation with the staffs of the House Ways and Means and Senate Finance Committees often will prepare a general explanation of the act. Bluebook: no legal effect. Bluebook: temporary guidance.
Evolution of tax law. Some provisions in the tax law take years to become law e. This process means that with each new Congress the measure had to be reintroduced until it finally gained the required support. An example of a provision that currently seems to be going through this process is the provision to tax carried interest at ordinary income rather than capital gains tax rates.
Deadwood bills. On occasion Congress will enact deadwood bills. Origin of a tax bill. Constitution mandates that revenue raising bills begin in the House. A tax bill might originate in the Senate when it is attached to other legislative proposals.
The Tax Equity and Fiscal Responsibility Act of originated in the Senate, and its constitutionality was unsuccessfully challenged in the courts. Naming tax legislation.
Some tax provisions are commonly referred to by the number the bill received in the House when first proposed or by the name of the member of Congress sponsoring the legislation. Coverdell Education Savings Accounts. Beginning in , the president was supposed to be able to cancel provisions from enacted tax legislation under the Line Item Veto Act.
Congress did not override these cancellations, but the constitutionality of the Line Item Veto Act was challenged in the court system and the Supreme Court held it unconstitutional. Tax legislation is referred from the Senate Finance Committee to the entire Senate. See Exhibits 2. Arrangement of the Code. In working with the Code, it helps to understand the format. The key is usually the section number. Mentioning Section 2 a is sufficient. Treasury Department Regulations.
Treasury decisions. Regulations carry considerable authority as the official interpretation of tax statutes. They are arranged in the same sequence as the Internal Revenue Code and have the force and effect of law. They are also concurrently issued as Proposed Regulations in order to become Final Regulations and automatically expire within three years after the date of issuance.
The IRS certainly tries to encourage tax fraud reporting by offering a portion of the resulting collections to the whistleblower. And is it ethical of the IRS to pay people to tattle on their tax-dodging literal and metaphorical neighbors, or should justice be its own reward? Validity of a Regulation. One way courts assess the validity of a Regulation is by the legislative reenactment doctrine. A Regulation is considered to have received congressional approval if the Regulation was finalized many years earlier and during the interim period Congress has not amended the relevant statutory language.
The I. Revenue Rulings and Revenue Procedures. The C. They usually deal with more restricted problems than Regulations and do not carry the same legal force and effect as Regulations. Revenue Procedures are issued in the same manner as Revenue Rulings, but they deal with the internal management practices and procedures of the IRS. Revenue Procedures do not carry the same legal force and effect as Regulations.
Punitive action e. Letter rulings. Letter rulings and determination letters have in common the fact that they apply only to the person who requested the ruling or letter. Note that neither is published by the IRS, but made available to private publishers.
Letter ruling. Revenue Rulings can result from a taxpayer request for a letter ruling. Determination letter. A determination letter is a statement issued by the Area Director in response to a taxpayer, which applies the tax law to a completed transaction. Precedential value. Under the doctrine of stare decisis, each decision has precedential value for future decisions with the same controlling set of facts.
The judicial process in general. After a taxpayer has exhausted some or all of the remedies available within the IRS, the dispute can be taken to the Federal courts. A taxpayer chooses the route to pursue a tax conflict from among four alternatives as illustrated in Exhibit 2. Court of Federal Claims hears tax and other monetary claims against the Federal government.
This court formerly was called the U. Claims Court. There is only one U. The court meets most often in Washington, D. Decisions are appealed to the U. Court of Appeals Federal Circuit. Tax Court hears only tax cases. Taxpayer does not pay the deficiency before trial. Court of Appeals Regional Circuit. Small Cases Division of the U. No appeal available. The broken line between the U.
No written record. The proceedings are informal, and there was no written record of such cases before Some of the more recent cases can now be found on the U. Tax Court website or in online research services. District Court hears tax as well as nontax cases. A jury trial is available. See Exhibit 2. Trial Courts. See Concept Summary 2. The differences among the various trial courts can be summarized as follows: Number of courts.
Number of judges. Jurisdiction of the Court of Federal Claims. Jurisdiction of the Tax Court and District Courts. Jury trial. Payment of deficiency. Termination of running of interest. Appellate courts. The two appellate courts are the Circuit Courts of Appeal 11 geographical circuits, the circuit for the District of Columbia, and the Federal Circuit and the Supreme Court see Exhibit 2. Bankruptcy court.
In certain situations, a bankruptcy court may have jurisdiction over tax matters. Since the filing of a bankruptcy petition prevents creditors from filing a claim against a person, a tax dispute may be settled by the bankruptcy court.
Locating court cases. Tax cases can be found in a variety of different official and unofficial sources. The instructor can utilize Figure in these Lecture Notes to explain the different sources in which tax cases are published.
The appellate process. The role of the appellate court is limited to a review of the trial record compiled by the trial court. The appellate process usually involves a determination of whether the trial court applied the proper law in arriving at its decision. Since the Golsen decision [Jack E. Golsen, 54 T. The U. Supreme Court grants certiorari to resolve a conflict among the Courts of Appeals or where the tax issue is extremely important.
The granting of a Writ of Certiorari indicates that at least four of the nine members of the Supreme Court believe that the issue is of sufficient importance to be heard by the full Court. Judicial citations. Judicial citations usually follow a standard pattern: case name, volume number, reporter series, page or paragraph number, court, and year of the decision. Beginning on October 29, , the Claims Court underwent a further name change.
The new designation, U. Court of Federal Claims, begins with Volume 27 of the former Cl. West citation now abbreviated as Fed. Claims Court and Court of Federal Claims decisions are now appealable to the Federal Circuit, whereas they were previously appealable only to the Supreme Court.
Court of Claims Reporter. The Court of Claims Reporter series, published by the U. Government Printing Office, is the primary source of these former Court of Claims cases. Federal Reporter and Claims Court Reporter. Court of Claims cases from to and from to September can be found in the Federal Reporter, published by West. Federal Claims Reporter. Beginning with Volume 27 on October 30, , the name of the reporter is changed to the Federal Claims Reporter.
Tax Court. Organization and authority. In , the Tax Court transitioned from an administrative court to a judicial court. Tax Court decisions. Regular Tax Court decisions are published by the U. Memorandum decisions. Memorandum decisions are reproduced by the government in mimeograph form only.
Tax treaties. Tax legislation enacted in provided that neither a tax law nor a tax treaty takes general precedence. If there is a conflict between the Code and a treaty, the most recent item takes precedence.
Loose leaf tax services. A number of publishers provide loose leaf or other currently supplemented tax services for practitioners. Some of the major services include: a.
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