tax research paper
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403_research_project_summer2016.docxACC 403 Tax Research Group Project for Summer 2016
Due Date: Wednesday, June 21, 2016.
You may work on this project in groups of 3 or 4 students per group. (Note that this is a “group” project and not an individual project.)
Your client (or professor) will not accept a late project (but will accept it early). Your client (or professor) will not be able to review your project in advance of its final submission (and projects submitted early will not be graded in advance of the due date).
Facts: Juan Alvarez is president of Alvarez Tech Corporation, a C corporation based in Palm Beach, Florida. He plans to purchase a new corporate jet that will be used by corporate officers and other employees to attend business meetings around the country. He said that too much time is now lost due to the airport security measures that have been implemented in the last several years and he believes that he could get a good price on the aircraft if he purchases it this year.
When the jet is not being used for business trips, it will be made available to the top four corporate officers for their personal use. Each of these officers is also a shareholder owning at least 5% of the corporate stock. Juan is looking forward to being able to fly to Aspen, Colorado on the new jet when he takes his family there to his favorite ski lodge. Juan wants to make sure that all of the expenses for the aircraft will be fully deductible by the corporation. He is aware that the officers may have some taxable compensation on their personal use of the jet. He wants to know what type of records he needs to set up to be able to determine the value of personal travel on the new jet and what methods are acceptable in determining that valuation. For example, can the corporation use the cost of a first-class ticket on a commercial aircraft as the amount that should be taxed to employees for their personal use?
Juan wants to make sure that if the corporation is audited by the IRS, he will have all of the required documentation. So he needs your assistance in determining if any limits will be placed on the company’s deduction for the jet ( his wants to maximize the deduction for the corporation ) and how to determine the amount of taxable compensation to the employees for their personal use of the job.
Required: Research the above issues for Alvarez Tech Corporation and prepare a “memo to file” as shown in your textbook on pages 87-88. Your memo should have four sections: (1) facts, (2) issues (stated as questions), (3) conclusions (short answers to each issue), and (4) discussion of your reasoning and authorities.
When writing the discussion section of your memo, start with the Internal Revenue Code section, then the Regulation section, then any relevant IRS rulings or other pronouncements, and finally any relevant court cases. Please be sure to include appropriate citations for any primary sources you cite. You can use secondary authority to assist you in locating primary authorities, but you cannot cite any secondary authorities in your memo to file (you must find the appropriate primary authority and cite only that). You do not need to prepare a client letter—only the memo to file. Submit one memo per group.
Watch the narrated PowerPoint presentation on how do to tax research using Checkpoint posted on Blackboard under Assignments (approximately 34 minutes).
Look under Web Links on Blackboard for a link to Checkpoint. You can access Checkpoint from anywhere you have an internet connection but you will need a user name and password to access it (see user names and passwords next to the link under Web Links on Blackboard). Only one student can use each user name at one time (so if you get the message that it is an invalid user name then it means that someone else is using that particular user name – so select a different one.) Checkpoint has a topical index that you may find easier to use than doing a keyword search.
Primary sources of authority that you can cite in your research memo include:
· Internal Revenue Code
· Regulations
· Court Cases
· Revenue Rulings
· Revenue Procedures
· Private Letter Rulings
· Technical Advice Memoranda
· Actions on Decisions
· IRS Notices
You cannot cite any editorial sources such as explanations, analysis, annotations, or similar summaries. These editorial sources may help you locate the above primary sources of authority, but you can only cite primary sources.
You also cannot cite instructions for tax forms. IRS will not accept its instructions for tax forms or general publications (such as IRS Pub. 17) as primary authority because they are intended only to assist the general public in filling out forms. These general publications do not go through the same detailed level of review at a national level as their other pronouncements listed above under primary sources.
Your professor (or client) will not be able to review your project in advance of its final submission so please so not ask the professor if you are on the right track in your research.
ACC 403 Tax Research
Group
Project
for
Summer
201
6
Due Date: Wednesday,
June
21
, 201
6
.
You may work on this
project
in groups of 3 or 4 students per group.
(
Note that this
is a “group”
project and not an individual project.)
Your client (or professor)
will not accept a late project (but will accept it early). Your client (or
professor) will not be able to review your project in advance of its final submission (and projects
submitted early will not be graded in advance of the due date).
Facts:
Juan
Alvar
ez
is president of
Alvarez
Tech
Corporation, a C corporation based in
Palm
Beach
, Florida
. He plans to purchase a new corporate jet that will be used by corporate officers
and other employees to attend business meetings around the country. He said that too
much time
is now lost due to the airport security measures that have been implemented in the last several
years and he believes that he could get a good price on the aircraft if he purchases it this year.
When the jet is not being used for business trips
, it will be made available to the top four
corporate officers for their personal use.
Each of these officers is also a shareholder ownin
g at
least 5% of the corporate
stock.
Juan
is looking forward to being able to fly to
Aspen
, C
olorado
on the new jet wh
en he takes his family there to his
favorite
ski lodge
.
Juan
wants to make sure
that all of the expenses for the aircraft will be fully deductible by the corporation. He is aware
that the officers may have some taxable compensation on their personal use of
the jet. He wants
to know what type of records he needs to set up to be able to determine the value of personal
travel on the new jet and what methods are acceptable in determining that valuation. For
example, can the corporation use the cost of a first
-
c
lass ticket on a commercial aircraft as the
amount that should be taxed to employees for their personal use?
Juan
wants to make sure that if the corporation is audited by the IRS, he will have all of the
required documentation. So he needs your assistance
in determining if any limits will be placed
on the company’s deduction for the jet (
his
wants to
maximize the deduction for the
corporation
) and how to determine the amount of taxable compensation to the employees for
their personal use of the job.
Required:
Research the above issues for
Alvarez
Tech
Corporation and prepare a “memo to
file” as shown in your textbook on page
s
87
-
88
. Your memo should have four sections: (1) facts,
(2) issues (stated as questions), (3) conclusions (short answers to each
issue), and (4) discussion
of your reasoning and authorities.
When writing the discussion section of your memo, start w
ith the Internal Revenue Code section,
then the R
egulation section, then
any
relevant IRS rulings or other pronouncements
,
and finally
any relevant court cases
.
Please be sure to include appropriate citations for any primary sources
you cite.
You can use secondary authority to assist you in locating primary authorities, but you
cannot cite any secondary authorities in your memo to file (y
ou must find the appropriate
primary authority and cite only that). You do not need to prepare a client letter
—
only the memo
to file. Submit one memo per group.
Watch the narrated PowerPoint presentation on how do to tax research using Checkpoint posted
o
n Blackboard under Assignments (approximately 34 minutes).
ACC 403 Tax Research Group Project for Summer 2016
Due Date: Wednesday, June 21, 2016.
You may work on this project in groups of 3 or 4 students per group. (Note that this is a “group”
project and not an individual project.)
Your client (or professor) will not accept a late project (but will accept it early). Your client (or
professor) will not be able to review your project in advance of its final submission (and projects
submitted early will not be graded in advance of the due date).
Facts: Juan Alvarez is president of Alvarez Tech Corporation, a C corporation based in Palm
Beach, Florida. He plans to purchase a new corporate jet that will be used by corporate officers
and other employees to attend business meetings around the country. He said that too much time
is now lost due to the airport security measures that have been implemented in the last several
years and he believes that he could get a good price on the aircraft if he purchases it this year.
When the jet is not being used for business trips, it will be made available to the top four
corporate officers for their personal use. Each of these officers is also a shareholder owning at
least 5% of the corporate stock. Juan is looking forward to being able to fly to Aspen, Colorado
on the new jet when he takes his family there to his favorite ski lodge. Juan wants to make sure
that all of the expenses for the aircraft will be fully deductible by the corporation. He is aware
that the officers may have some taxable compensation on their personal use of the jet. He wants
to know what type of records he needs to set up to be able to determine the value of personal
travel on the new jet and what methods are acceptable in determining that valuation. For
example, can the corporation use the cost of a first-class ticket on a commercial aircraft as the
amount that should be taxed to employees for their personal use?
Juan wants to make sure that if the corporation is audited by the IRS, he will have all of the
required documentation. So he needs your assistance in determining if any limits will be placed
on the company’s deduction for the jet (his wants to maximize the deduction for the
corporation) and how to determine the amount of taxable compensation to the employees for
their personal use of the job.
Required: Research the above issues for Alvarez Tech Corporation and prepare a “memo to
file” as shown in your textbook on pages 87-88. Your memo should have four sections: (1) facts,
(2) issues (stated as questions), (3) conclusions (short answers to each issue), and (4) discussion
of your reasoning and authorities.
When writing the discussion section of your memo, start with the Internal Revenue Code section,
then the Regulation section, then any relevant IRS rulings or other pronouncements, and finally
any relevant court cases. Please be sure to include appropriate citations for any primary sources
you cite. You can use secondary authority to assist you in locating primary authorities, but you
cannot cite any secondary authorities in your memo to file (you must find the appropriate
primary authority and cite only that). You do not need to prepare a client letter—only the memo
to file. Submit one memo per group.
Watch the narrated PowerPoint presentation on how do to tax research using Checkpoint posted
on Blackboard under Assignments (approximately 34 minutes).
