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

Gregory R. and Lulu B. Clifden tax return, Gregory R. and Lulu B. Clifden l...

Gregory R. and Lulu B. Clifden live with their family at the Rock Glen House Bed &Breakfast, which Gregory operates. The Bed & Breakfast (B&B) is located at 33333 Fume Blanc Way, T

Nature payment, interest of late payment tds nature of payment code

interest of late payment tds nature of payment code

Determine the taxable income and tax payable, Justin's parents operate a re...

Justin's parents operate a restaurant business through a family trust, The Pepper Family Trust, which had the following receipts and expenses for the year ended 30 June 2011 (the b

Study case of an exam of GST in new zealand, my level Master of the Paper G...

my level Master of the Paper GST ( law) I have an exam case I have already answered I need to revise the high level tutor ( 5000 words) Can you help me?

What is the total income effect for the year, Given the below facts, what i...

Given the below facts, what is the total income effect for the year for an investor for its passive-level, trading investment? (Note: the investment is not sold during the year.)

Tax-exempt commercial paper, An unsecured short-term loan, generally issued...

An unsecured short-term loan, generally issued to finance short-term liabilities, which gives the debt holders (bondholders) some level of tax choice on the earnings from their deb

Tax return preparation, WriteRight, Inc. has engaged us to prepare its 2012...

WriteRight, Inc. has engaged us to prepare its 2012 Federal (but not state) income tax return. Your responsibilities are as follows: 1. Prepare WriteRight, Inc.'s 2012 Federal

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