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

Corporate Taxation, do you offer tutoring services for graduate accounting ...

do you offer tutoring services for graduate accounting students?

IRA, Donald, a 40-year-old married taxpayer, has a salary of $55,000 and in...

Donald, a 40-year-old married taxpayer, has a salary of $55,000 and interest income of $6,000. What is the maximum amount Donald can contribute to a Roth IRA?

Tax umbrella, The use by a corporation of the losses it continued in earlie...

The use by a corporation of the losses it continued in earlier years to compensate taxes on the profits it attains in future years. Individuals can also utilize a tax umbrella so t

Tax rates, Taxable income Tax on this income ...

Taxable income Tax on this income $0 - $37,000 29c for each $1 $37,001 - $80,000 $10,730 plus 30c for each $1 over

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

Research, Assignment 1 (from chapter 1) Ahi Corporation is one of your clie...

Assignment 1 (from chapter 1) Ahi Corporation is one of your clients in Hawaii. The company had a good year last year and owes the IRS $100 million, due on March 15. There are no p

Capital gains tax and inheritance tax issues , Background information J...

Background information Jim set up a limited company; Show the Way Limited (The Company), along with his father in 1983. The company is incorporated in Scotland and has been reg

How long, How long should receipts be kept?

How long should receipts be kept?

Calculate tax liability, Tax Liability Calculation Morgan (age 45) is singl...

Tax Liability Calculation Morgan (age 45) is single and provides more than 50% of the support of Rosalyn (a family friend), Flo (a niece, age 18), and Jerold (a nephew, age 18). Bo

Vat, meaning of vat

meaning of vat

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