TAX exam

Final Exam Guidelines

· The final exam includes eight questions.

· The exam is due on 3/31/2013 by 11:59 P.M.

· Points will be deducted if the exam is submitted late.

· All eight questions need to be answered and submitted on time.

· The exam counts as 250 points towards your final grade.

· Prob 1 = 20 points

· Prob 2 = 40 points

· Prob 3 = 40 points

· Prob 4 = 30 points

· Prob 5 = 30 points

· Prob 6 = 25 points

· Prob 7 = 40 points

· Prob 8 = 25 points

· Problem #1

· In your solution to the problem, include the following:

· 3-4 primary steps you followed to solve the problem.

· Reference any court cases for support.

· Use RIA Checkpoint for keyword searches

· State your conclusion at the end.

· Length: Half page max.

Problem #2

Consider the following when answering the question:

· Length: Memo should be limited to 2 pages

· Include code references

· Advantages and Disadvantages of incorporating

· Non-tax

· Tax

· Discuss the types of entities that would apply and make a recommendation

· Discuss check-the-box

· Problem #3

· At a minimum, the memorandum should address:

· Will the advance be recharacterized as equity instead of debt?

· Will the unavailability of alternative financing at “reasonable rates” be significant in any decision to recharacterize?

· Analogy between the Tomlinson case and the case in question.

· Dissimilarities that might undermine application of the Tomlinson case.

· Consider the factors within the Rudolph A. Hardman case and how do they apply to the case in question.

· Length: No more than 2 pages.

· Problem #4:

· Refer to pages 3-25 through 3-28.

· Length: Less than a half page.

Problem #5:

When answering this question, you may want to consider preparing a chart.

· In the chart show the tax basis and at-risk basis for the partners.

· Refer to IRC 465(b)

· Length: Less than half a page.

Problem #6:

· When answering this…

· Refer to pages 10-26 through 10-28 for some supporting material.

· Length: Less than half a page.

· Problem #7:

· Refer to pages 11-19 through 11-22 for additional supporting material.

· Reg. Sec. 1.752-2(c)(1)

· Length: No more than one page.

Problem #8:

· Standard calculation of the estate tax base.

· No need to include any additional text.

· Show the items that were factored into your calculation of the estate tax base.

· Length: Less than a half page.