Tax court, Taxation

Assignment Help:

1. Although she left her job in November of Year 1, Patrice was entitled to a year-end bonus. On December 30, her former boss called her to let her know the check was available. Patrice did not pick up the check until January 3, Year 2. Her W-2 for Year 1 did not include the bonus, so Patrice did not include it in gross income for her Year 1 tax year when she filed the return on April 15, Year 2. In Year 2, she received a W-2 in the amount of the bonus, but Patrice decided she should have included it in her Year 1 gross income because she "constructively received" it in Year 1. Therefore she did not include it in her Year 2 return, which she filed on April 15, Year 3.

On May 1, Year 5, the IRS mailed Patrice a notice of deficiency for her Year 2 tax year based on the unreported bonus. Patrice petitioned the Tax Court, and on June 1, Year 6, the Tax Court's decision in Patrice's favor became final. The decision was made on the ground that the bonus should have been income for Patrice's Year 1 tax year. The statute of limitations on assessment for Year 1 expired in Year 5.

A- What recourse does the IRS have?

B- If the IRS has an option under part A, what action would it have to take, and by what deadline?

Question 2:

Gail filed her Year 1 return on April 15, Year 2. On March 3, Year 5, the IRS asked Gail to agree to extend the statute of limitations on assessment. On March 5, year 5, Gail signed a Form 872, specifying an extension of the statute until April 15, Year 6. Subsequently, Gail signed additional  Forms 872, on April 1, Year 6 and May 1, Year 7, each providing an additional 1-year extension. When is the last day that the IRS can send Gail a notice of deficiency as a prerequisite to assessing tax with respect to Gail's Year 1 tax year?

Question 3:

Darcy has received a notice of deficiency from the IRS in the amount of $20,000.

A- What should Darcy do if she wishes to dispute the notice in Tax Court?

- Does she have to pay the deficiency at this point?

-  Is she precluded from paying the deficiency at this point?

B- Assume that Darcy believes that the notice is incorrect, and that she is actually entitled to a refund of $10,000. May she litigate in Tax Court both the issues in the notice and the issues she believes entitle her to a refund?

Question 4:

George received a notice of deficiency on February 20, Year 4 with respect to his Year 1 return. The notice of deficiency is based on unreported income. George timely petitioned the Tax Court on April 9, Year 4. Several months before trial, on June 1, Year 5, the IRS raised an additional issue (the disallowance of certain deductions on his Year 1 return), and moved to amend its answer to the petition. What procedural defenses or arguments can George raise with respect to the new issue?

Question 5:

On April 20, Year 4 Sheila received a notice of deficiency from the IRS with respect to her Year 1 taxable year. The notice was dated December 1, Year 3. It had been mailed to her prior address, where her former roommate still resides. Sheila filed her Year 2 and Year 3 returns after moving to her current address, and that address was on those returns. Sheila also has a forwarding order in with the Post Office, but they delivered the notice to her old address anyway. Her former roommate apparently received the envelope but did not open it. She finally put it in the mail to Sheila with some other documents; Sheila received it yesterday and brought it to you to ask what to do. She is concerned because the notice reflects an asserted deficiency of $50,000, which she cannot afford to pay in full. What do you advise?

Which taxpayer rights have been weakened by the Uncertain Tax Position disclosure requirements?


Related Discussions:- Tax court

Tax liability calculation, The XYZ Corporation has total earnings of $20 mi...

The XYZ Corporation has total earnings of $20 million and decides to pay its stockholders a dividend of $8 million. If the corporate tax rate is 30% and the personal tax rate on in

Calculate income tax for company, Microrax Company earned before-tax income...

Microrax Company earned before-tax income of $960,000 for its 2013 fiscal year. During the year the company experienced a $605,000 loss from earthquake damage that it considered to

types of taxes, An organization in Australia needs to comply with the stat...

An organization in Australia needs to comply with the statutory requirements of taxation. There are different types of taxes among which a few are common for all the industries and

Tax credit for the elderly and disabled, Tax Credit for the Elderly and Dis...

Tax Credit for the Elderly and Disabled - Taxpayers age 65 or older or those under 65 who are retired with permanent and total disability are entitled to claim a credit to decrease

Maximum loan amount, 1. (a) Give an example of a function, f(x), that has a...

1. (a) Give an example of a function, f(x), that has an in ection point at (1; 4). (b) Give an example of a function, g(x), that has a local maximum at ( 3; 3) and a local minim

federal tax payable, During 2011, C Ltd. A public corporation has net inco...

During 2011, C Ltd. A public corporation has net income for tax purposes of $600,000 including $100,000 of dividends from taxable Canadian corporations and $500,000 of retailing pr

Sales tax, Arnold and Beth file a joint return. Use the following data to c...

Arnold and Beth file a joint return. Use the following data to calculate their deduction for AGI. Mortgage interest on personal residence $ 4,000 Property taxes on personal resi

Calculate taxable income, Temporary difference; future deductible amounts; ...

Temporary difference; future deductible amounts; taxable income given Lance Lawn Services reports warranty expense by estimating the amount that eventually will be paid to satis

Calculate the change output growth , Utilize Okun's law to answer the quest...

Utilize Okun's law to answer the questions below;  u t  - u t-1  = -0.4(g yt  - 3%) Assuming u t-1  = 7% a. Calculate the change in u (u t  - u t-1 ) for each of the followin

Write Your Message!

Captcha
Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd