Research Memo Date: February 27, 2014 Preparer: Michele Reviewer: Brian Subject: Personal use of Delta Skymiles acquired from company purchased business trips Facts: Latrell recently used his Delta Skymiles to purchase a free roundtrip ticket to Milan, Italy (value $1,200). The frequent flyer miles used to purchase the ticket generated from Latrell’s business travel as a CPA. Latrell’s employer paid for his business trips, and he did not get taxed on the travel reimbursements. Issue:
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TAX RESEARCH MEMO TEMPLATE June 30, 2015 Relevant Facts Robert Jones has just rendered service for a taxpayer as an expert witness in a case heard by the U. S. Tax Court. The taxpayer is requesting reimbursement for Jones’ fees and for those amounts paid to her attorney in presenting the case. Jones’ billing rate for this type of engagement is $500 per hour, the market rate for such services in his city, plus out- of- pocket expenses (e. g., auto mileage, computer charges). Specific
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penalty paid to a government for the violation of any law. The $8 million payment cannot be deducted because it reduced the fine for $15 million to $7 million. If the IRS allowed the deduction it would be a double benefit to the taxpayer. The Income Tax Regulations states that a fine or similar penalty includes any amount paid in settlement of the taxpayer’s conduct or potential liability for a fine or penalty whether civil or criminal. (Treasury Regulations Section 1.162-21(b) Courts generally differentiate
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fully refundable until the date the goods and services are provided. Analysis Peaceful’s situation is similar to the case COMM. v. INDIANAPOLIS POWER & LIGHT CO., Cite as 65 AFTR 2d 90-394 (110 S.Ct.589), 01/09/1990, Code Sec(s) 61, where the tax court ruled that the prepayments principal purpose is to serve as security rather than a prepayment of income. Since all prepayments to Peaceful were deemed refundable, they too serve as security rather than income. Since the payments are not “advanced
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worth of home accessories and an all-expense paid trip to Disney World. During the lease term, Surprise Home Renovation expensed approximately $250,000 in renovating and remodeling the Sanchez home. The Sanchez’ would like to affirm the potential tax consequences of the engagement with Surprise Home Renovation. Issues 1. Should the consideration of the lease be considered rental income, prize, or neither? 2. Was the consideration received, or a portion thereof, for the leasehold rights
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To: Mr. Keith’s Estate Facts: 1. Mr. Keith and Mr. Lars were business partners for 30 years. 2. Each partner had a life insurance policy on the other partner so that the insurance proceeds could be used to purchase the deceased partner’s interest in partnership from his estate. a. Each partner was allowed veto power over any beneficiary that was chosen or changed on the life insurance policy that was on his own life. 3. Mr. Keith died recently and Mr. Lars received the $500,000 life insurance
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$20,000)] (12,500) 57,500 E&P before distribution $212,500 Minus: Cash distribution (100,000) Property distribution (100,000) E&P, December 31 $ 12,500 *E&P and tax gains are the same. Both distributions are fully taxable as dividends to Jeff and John in the amount of $100,000 each. John takes a $100,000 FMV basis in the land he receives. b. AAA, January 1 $125,000 Current year
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Tax Memo Suzzanne Gross Summary of Facts Suzzanne Gross was former Chief Operations Officer of a mid-sized engineering firm called Anebako. She was also an investor in several projects that the firm undertook. Suzzanne supervised up to twelve engineers at the firm. A co-worker accused Suzzanne of sexual harassment. The company interviewed the initial accuser and decided to investigate the matter further. All of Suzzanne’s reporting engineers were then interviewed. Suzzanne eventually resigned
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is debt treated at bankruptcy? 2. What are the tax consequences of contributing capital to a corporation when the company goes bankrupt? 3. If a loan is structured with the intent to protect investment, what are the tax consequences when the company goes bankrupt? 4. If a loan is structured to protect employment, what are the tax consequences at the time of bankruptcy? 5. Which of the above scenarios is the best way to structure a transfer for tax purposes? Conclusions 1. Debt will become wholly
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| AC 472 | Memo To: | Dr. Greg Carnes | From: | Will Lamon | cc: | Rebecca Hamm | Date: | 3/17/2015 | Re: | Professional Assignment # 3 | | | Dr. Carnes, The article dealing with Tiger Woods and his alleged deal that he struck with Men’s Health has some potential areas that are in need of clarification. American Media, the owner of National Enquirer and Men’s Health was able to, nonchalantly force Tiger Woods into doing a cover shoot for the magazine. This article vividly illustrates
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