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Mike Brown

ACCT 429 Week 7 Research Project

Mike Brown

ACCT 429 Week 7 Research Project

https://homeworklance.com/downloads/acct-429-week-7-research-project/

 

Performing tax research is an importa

nt part of tax practice. As outlined in Chapter 2 of your

textbook, tax law is developed through a number of different governmental entities. Congress

enacts the tax Code as statutory law. The Treasury Department is tasked with the

implementation of the

tax Code and, in the course of doing so, develops a number of

documents and materials to aid taxpayers in understanding the Treasury Department’s

interpretation of the code, including the Regulations. In turn, the Internal Revenue Service

(“IRS”) has the

direct responsibility for

implementing the tax Code and in assessing and

collecting the applicable tax from taxpayers. In the course of its duties, it also develops a

number of materials, including Revenue Rulings, Revenue Procedures, and Private Letter

Rulings, in which it sets forth its understanding of the tax laws. Finally, the federal courts

decide tax cases in which taxpayers contest the government’s interpretation of the tax laws. In

deciding these cases, the federal courts set forth binding inte

rpretation of what the tax laws

provide. All of these materials (often called primary resources) are important resources in

performing tax research. On top of these primary sources of tax law, there are a number of

secondary materials provided by various

organizations and publishers. These secondary

materials offer editorial analysis of the tax laws (somewhat akin to a Cliffs’ Notes

®

on tax laws)

to help tax practitioners understand the tax laws and apply them in given situations.

Just as with the first

project that was submitted in Week 3, t

he following assignment has

three

(

3

) different graded elements. Two of them require you to prepare tax file memoranda, while

the

remaining element requires

you to compose an essay answering the question asked. AS

S

UCH, YOU WILL BE SUBMITTING

THREE

SEPARATE DOCUMENTS FOR THIS ASSIGNMENT.

1.

The first two assignments require you to compose tax file memoranda. In each of these

problems, you will be given a fact pattern or issue that requires you

to decide

or analyze

a particular issue of tax law. You will also be provided with a number of the primary

sources discussed above

(

e.g.

, Revenue Rulings, cases)

on that issue of tax law.

You will

then compose a tax file memoranda concerning that taxpayer.

You can find det

ails as to

how to compose such a memorandum in Chapter 2 of your text, including a sample text

file memorandum in Figure 2.6 on page 2

26 of your text. Use the materials provided to

determine the proper solution to the taxpayer’s issues. In particular, d

iscuss the

materials in some detail in the “Analysis” section of the tax file memorandum. THIS IS

IMPORTANT! The most important part of any tax file memorandum is the thoroughness

of the analysis defending the conclusion reached in the memorandum. Accor

dingly,

most of the points awarded on the assignment are allocated to the “Analysis” sect

ion of

the memorandum. In assessing these assignments, consideration will be given to,

among other factors, (1) your accuracy in summarizing the relevant facts; (2) t

he

accuracy of your identification and statement of the “Issue” presented by the problem;

(3) the accuracy of your “Conclusion;” (4) the thoroughness and quality of your analysis

Week

7

Research Project (Set #

1

)

DeVry University Acct 429

offered in the “Analysis” section of your memorandum; and (5) the overall

pro

fessionalism of your memorandum (

e.g.,

presentation, use of proper grammar,

proper spelling, and quality of communication).

EACH OF THE TAX MEMORANDA

IS

WORTH

30

POINTS

, FOR A TOTAL OF

60

POINTS

.

2.

The remaining assignment require

s

you to perform some rese

arch on the Internet to

find relevant materials and to

analyze these materials.

As previously noted, in

performing this research, you may not take advantage of any resources other than those

specifically permitted by the assignment, including assignments

previously completed by

other students or other similar materials.

You will then complete an essay answering

the question or questions presented by

this

assignment. Your submission will be graded

on a number of factors, including (1) your ability to loca

te relevant research and

materials on the Internet; (2) your ability to analyze these resources; (3) your ability to

draw conclusions from these resources and to defend these conclusions with analysis of

the research and materials located; and (4) the over

all professionalism and content of

your essay (

e.g.,

presentation, use of proper grammar, proper spelling, and quality of

communication).

TH

IS

ESSAY

IS

WORTH

20

POINTS.

Please note that these assignments are worth a significant portion of your grade. As

such, you

should take them seriously, and leave yourself enough time to complete them. Do not wait

until the last weekend to begin these assignments. If you do, it will be very difficult for you to

submit quality responses to each of the four questions o

r problems posed. Please also note

that preparing these answers conscientiously will help you in preparing for the final

examination, given that you may be required to perform similar analyses on the exam. Should

you have a question, please ask your inst

ructor. Good luck!

Week

7

Research Project (Set #

1

)

DeVry University Acct 429

TAX RESEARCH MEMORANDUM ASSIGNMENT 1

As we learned in Week 4, the Code allows taxpayers to take a deduction for the cost of meals

when taxpayers have been deemed

to be “away from home” for tax purposes. This

determination can be difficult. Two separate clients came to you with questions as to whether

they are entitled to take a deduction for the cost of meals incurred during a particular trip. The

facts pertaini

ng to each are:

1.

Tracey is a sales representative for a national pharmaceutical company. She has a

rather large sales territory, and she makes her rounds to her customers using a

company

owned car over a 16

to 19

hour period of time. During these one

day

business trips, Tracey will pull over in a suitable location (such as a park or a rest

stop) and take a short nap in the backseat of her automobile.

2.

Mark captains a ferryboat. This ferryboat carries tourists on roundtrips from Seattle

to Victoria and

back, each trip of which lasts from 15 to 17 hours and provides for a

6

to 7

hour layover in Victoria. During the layover, Mark typically takes a four

hour

nap on a cot that he has stored in the pilothouse of the ferryboat.

Under each of these circumstan

ces, if the taxpayer entitled to deduct the cost of meals

purchased during the trip at issue?

COMPOSE A TAX FILE MEMORANDUM CONCERNING THIS ISSUE

FOR BOTH TAXPAYERS

USING

THESE FACTS AND THE RESEARCH MATERIALS PROVIDED

TO YOU IN THE NEXT FEW PAGES (

30

POI

NTS)

 

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