835 exam 1 fall 2019.doc - Name_Xiaomin Zhang Acct 835 Exam 1 Fall 2019 Submit solutions to the following via email by 10 p.m October 7 1 If a Nebraska

835 exam 1 fall 2019.doc - Name_Xiaomin Zhang Acct 835 Exam...

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Name ___ X iaomin Zhang________ Acct. 835 Exam 1 Fall 2019 Submit solutions to the following via email by 10 p.m., October 7. 1. If a Nebraska taxpayer loses a case to the IRS in Nebraska Federal District Court, the specific court to which the taxpayer would appeal the case is _U.S. Court of Appeals Eighth Circuit________. 2. If the IRS loses a case to a Kansas taxpayer in Tax Court, the specific court to which the IRS would appeal the case is __U.S. Court of Appeals Tenth Circuit___. 3. Name the courts which have opinions published in the American Federal Tax Reports (AFTRs). Federal District Courts, Federal Circuit Courts of Appeal, and the U.S. Supreme Court 4. Name the Subchapter of the Internal Revenue Code in which Section 1245 is found. Subchapter P – Capital Gains and Losses 5. The least authoritative type of Treasury Regulation is _proposed regulations___. 6. The Internal Revenue Code Section addressed in Private Letter Ruling 9827040 is _Code Section 451________. 7. The citation for the opinion of the highest court to consider O’Gilvie v. U.S. is __78 AFTR 2d 96-7454 (117 S.Ct. 452)______. 8. A parallel citation to 349 F. 3d 102 is _2003-2 USTC P 50714____. 9. The court to which any appeal from 349 F. 3d 102 would have been made is __U.S Court of Appeals, Third Circuit_________. 10. Rev. Rul. 95-58 was cited favorably in Private Letter Ruling _9607008 and 9809032________. 11. Between a Temporary Regulation and a Revenue Ruling, the more authoritative is __Temporary Regulation______. 12. Regulation Section 1.731-2(e)(4) is an interpretation of Internal Revenue Code Section __ 731(c)(3)(C)(iv)_______.
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13. The only Federal Court that hears exclusively tax cases and no other type of case is ___United States Tax Court_____. 14. In the citation, IRC Sec. 101(a)(2)(B) a) the (a) stands for __Subsection a___ b) the (2) stands for __Paragraph 2__ c) the (B) stands for __Subparagraph B_ 15. Describe the general contents of each of the following in the Internal Revenue Code a. Section 751 Unrealized receivables and inventory items b. Subtitle A, Chapter 2 Income Taxes – Tax on self-employment income c. Subchapter J Estates, Trusts, Beneficiaries, and Decedents d. Subchapter K Partners and Partnerships e. Subparagraph B of paragraph 1 of subsection C of Section 732. To the extent of any basis remaining after the allocation under subparagraph (A), to other distributed properties – 16. Describe the general contents of each of the following a. Private Letter Ruling 200113020 “Qualified scholarship” portion of fellowship grants and stipends paid to participants in tax-exempt educational organization's training program aren't wages and aren't includable in recipients' gross income. b. Rev. Rul. 2008-5 Loss from wash sales of stock or securities—sale followed by purchase by IRA. In situation where taxpayer sells stock at loss and then next day purchases same quantity of identical stock for his IRA or Roth IRA, loss is disallowed under Code Sec. 1091; and basis in IRA isn't increased under Code Sec. 1091(d); . Even though IRA is tax-exempt trust, taxpayer has “acquired” (for purposes of Code Sec. 1091(a); ) stock purchased for IRA: overly strict construction shouldn't be applied where
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  • Spring '14
  • JeffreyJ.Bryant

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