Essays on Internal Revenue

THE IMPACT OF THE CHANGE OF TAX YEAR ON THE CORPORATION’S APPLICATION FOR A CASH GRANT ON THE INVESTMENT MADE IN QUALIFYING THERAPEUTIC DISCOVERY

In the Silver Medical, Inc. V. Commissioner of Internal Revenue (2016), the respondent, the commissioner of internal revenue, determined a deficiency in the Silver Medical, Inc.’s Federal income tax amounting to 41,032 US dollars for the fiscal year ending on 30th November, 2011 along with an accuracy related fine amounting to 8,206 US dollars (Leagle, Inc., 2016). The case was filed on 19th December 2016. The United States Tax Court held ...

Federal funding for the restoration and protection of coastal wetlands

The federal government has an exclusive jurisdiction over protection and restoration of coastal wetlands that are deemed by DEC as of local importance. The federal government is statutorily authorized to adopt and implement a coastal wetlands protection law wholly or partially within the federal government’s jurisdiction. The law prescribes specific funding and procedures be followed in determining the extent of the coastal wetlands hazard while seeking to assert its jurisdiction over its coastal wetlands. The systems of the coastal wetlands protection necessitate forwarding of the federal government’s regulation to DEC for the establishment of the competence of ...

Abstract

The study seeks elaborate on the nonprofit and for-profit hospital joint venture and giving growing similarities in their operation capacities. The growing need for improvement by nonprofit hospitals regarding healthcare delivery requires high capital generation and more funding. Overdependence on sponsors and well-wishers for grants do not support the community benefit fully. This makes nonprofit hospitals not to deliver high quality health care, and unable to settle bills and outsourcing high technology to support medication. The conversion from nonprofit to for-profit hospital, and joint venturing with for-profit hospital help in improving performance, delivery, and high-quality health care. The paper ...

As your authorized legal adviser on the matters that you have disclosed, I have attached the necessary legal challenges that you are faced with and finally the best possible way of avoiding legal action by complying with the set out legal regimes.

Facts

Reading the information that you have availed in regards to receiving a w9 from your foreign bank, this may elicit many questions as may relate to the reasons of receiving such a letter as well as the consequences of receiving such a letter. However, I will guide you into pursuing the best option to explore since you ...

1. United States v. Cesarini, 296 F.Supp. 3 (N.D. Ohio 1969), is a historical case that decided by United State District Court, the court ruled that property for treasure trove included in gross income for the tax year when realized. 2. § 1.74-1 Prizes and awards. b) Excluded from gross income. Section 74(b) it happens when such prize or award was made solely in recognition of achievements in the past of the recipient in religious, charitable, literary, educational, artistic, or civic fields (Arkin) 3. Yes. It's not common within the IRS, section 7430 of the Internal Revenue Code. IRC ...

Essay one (China’s financial system)

Introduction and Thesis Statement The restoration of an economy from a depression requires a careful adoption of strategies. Various measures that governments use to promote the growth of key sectors as wells the entire economy have severe outcomes which must be considered before they are put in practice. Fundamentally, governments implement different fiscal and monetary strategies to solve economic problems, which may be successful or not. Thus, the analysis of the strategy to be deployed becomes essential to achieve the desired objectives. The financial sector in an economy is of central importance. As such, public policies that impact on ...

Find and properly cite a case in which the taxpayer and the IRS disagreed as to whether the taxpayer was bound by the terms of a closing agreement entered into in connection with a prior audit.  Answer: United States v Booker 543 US 220 (2005) Find and properly cite a case decided after the year 2000 in which a Big 4 accounting firm litigated the issue of whether either (i) its work papers or (ii) its communications with a client were protected from discovery by the IRS (i.e., the IRS had issued a summons to the accounting firm). Also ...

Question OneDoes the IRS view the cost of laser eye surgery (“LASIK”) as a valid § 213 medical expense deduction – or, alternatively, is it nondeductible cosmetic surgery? Yes, it is viewed as a valid medical expense deduction as it promotes the proper functioning of the body under § 213(d) (9). (IRS Publication 502, 8) Question Two Brother and sister operate a farm as a family corporation inherited from their parents. Differences over how the farm should be operated have led to a serious breakdown in their relationship. Is this a sufficient “business purpose” to support a tax-free split-up per § 355?  ...

Section 195 of the Internal Revenue Code encompasses the provisions concerning amortization of the start-up expenditures and is applicable to any trade or business. Start-up expenditures include all the money spent on creation of a trade or business or investigation of the creation or acquisition of an active trade or business, as well as on any activity that is supposed to bring profit before the beginning of active trade or business (Internal Revenue Code). Start-up costs can be amortized if they meet the following criteria: they incurred for operation of the existing active trade or business in the same ...

There is a considerable and sizeable population of small business in the US economy. Statistically speaking there are over 28 million small business that occurs with small business specifically indicating businesses with fewer than 500 employees. Over 22, million individuals are self-employed without any additional payrolls or having employed other persons. Of the working population, a considerable percentage of over 50% that translates to 120 million individuals work in the small business (US statistics and data, 2016). Small business on average have modest turnovers that attract income taxes on the cash generated. Business entities are relevant in the generation ...

The world today operates in an age of IT. Almost every bit of our daily life activities has been computerized: most services and access to information is now automated, even business transactions. With such advancements in Technology (particularly access to information), comes the need for privacy and security on individuals, companies and corporate entities. For instance, most people in the world today acquire products and procure services in the form of cashless transactions. These transactions are facilitated through the use of a payment card. The payment card is given to the payment card holder, as representation of account with ...

Would Pharma Corporation be eligible to be an S Corporation? If one of the shareholders objected, would the other two do a vote to become an S corporation without the third? Legally speaking, Pharma Corporation can become whatever type of corporation it wants to be. It is necessary, however, that it be able to fulfill all the regulatory and procedural requirements set by the federal and local government needed to obtain certification for being their chosen type of corporation. This means that Pharma can become an S Corporation. The United States Internal Revenue Service (IRS) defines S Corporations as “ ...

Over the last three years I have had the honor of managing several interesting people. As an Area Manager for Jackson Hewitt Tax Services, I spent a great deal of time working with franchise owners, general managers and tax preparers. There were times when it was both overwhelming and rewarding. As a part of the management team, I felt that anything could be accomplished. But, how quickly that can change. The area that I managed consisted of nine stores. My team consisted of 25 people who were to be able to prepare a certain amount of tax returns per ...

Facts

With the pending merging of two businesses on the basis of family, the valuation of the newly formed Messina Propriety Inc. is suggested to be a direct market value combination of the values of the two companies. This cumulatively stands at $ 3,600,000. The merger will see the three Messina’s has a 62.2% holding for Tony Messina, 15.6% for Martin Messina and another 22.2% for Tony Jr. Looking at the basis of shareholding in the two companies, Tony holds 600,000 ordinary shares , which is double what Martin owns in their company. On the other end, Tony ...

Greetings Ms. Cherie Logan,

The purpose of this document is to provide you with the legal background of the scenario that you and the corporation that you are a part of, Cincinnati Commercial Design Associates Inc., is facing.

Facts

Starting with the facts, it has to be stated and clarified that you started the business—which is now running as a corporation, as a sole proprietorship or a privately owned business for an undisclosed number of years and that the main reason behind the recent step to incorporate it was to minimize potential liabilities as a business owner. The petition for Cincinnati Commercial Design ...

Research Paper

Abstract Max Weber has greatly influenced both private and public organizations through his conception of bureaucracy, which he describes as the most efficient, productive structure for any formal organization. He developed the six-point ideal type model as a pattern for formal organizations wanting to streamline and rationalize their systems. However, Weber also recognizes some of the disadvantages of bureaucracy, such as its negative impact on employee morale and customer satisfaction and organizational productivity. Trained incapacity is one of the concepts that explain how bureaucratic practices make formal organizations too rigid or inflexible. This paper critically evaluates and discusses Weber's ...

I. Introduction Now & Then Financial Services is a financial services company founded by Jason Mleczko, LaSand Kinnaird and Rebekah Ostby. The company, which is headquartered in Harrisburg, Pennsylvania, seeks to provide financial management products and services to new income earners such as recently graduated college and university students. Based on the company’s mission and goals, target market to be served, and inherent risks in establishing and running a start-up business, Now & Then Financial Services has decided to incorporate as a non-profit corporation. A non-profit corporation is defined as a business type where the purpose of the business is ...

The issue at hand is that the client some information that is questionable and further clarification is needed. However, the client is not cooperative since she is not willing to provide any further information. Without the information, it may not be possible to complete the tax returns accurately. Besides, she needs the financial statement prepared within one week. It is an ethical dilemma. Completing the financial statements and income tax returns without the information will result in misrepresentation of the financial position and financial performance of the company. Third parties including the bank will rely on the financial statements ...

At present, the number one criminal activity of gangs include drug-trafficking of cocaine and marijuana since it an easy money-making scheme. For the past decades, the legalization of marijuana has been the subject of an enduring debate due to its long term effects in society. However, the lawmakers must consider not only the medicinal benefits of cannabis derivatives, but also its economic prospective and how it can affect the law enforcement agencies. Cannabis should be legalized nationwide to give the public the option to take a holistic approach to the illness instead of using addictive prescription drugs, will generate ...

Introduction

Question 1

The governments contented that its claim for Atlantic Trading Company income taxes ,was claimed to be entitled to first priority rule as an administrative expense instead of the unsecured tax claim since the said taxes of the state were not just any tax but tax specified in the 507(a)(7)(A)(iii) pursuant to 503 (b) (1)(B)(i). The government failed to file the immediate proof of the claim. Since the company made profits in which it was to remit some percentage to the government, the government was not supposed to make administrative expenses on the company. The ...

Executive summary 1

Statement of problem 2 Controlling Authorities 5 Possible Solutions 6 Solution 1 6 Diversity in Expertise 7 Professionalism and Ethics 7 Increased Goodwill 7 Big Costs 7 Option two - hiring an in-house counsel. 8 Minimal costs 8 Accessibility to the documents 8 Shared Ethics and Value 8 Lack of Professionalism in Specific Areas 8 Continual training inadequacy 8 The legal model for XTRA Technologies 9 Conclusion 9

Works Cited 10

Executive summary The majority of business analysts agree on the idea that legal compliance is ...

The law of property act of 1925 is among the Acts that were designed as part of the integrated legislative program initiated by Lord Chancellor Lord Birkenhead between the year 1921 and 1925 (Beale Jr. 1907). This piece of legislation primarily concerns itself with the transfer of property. In law, the word property is synonymous with the word land. There are many reasons that explain why land is the most fundamental kind of property in society. The provisions relating to the law of property are principally concerned with the transactions on matters of land, most prominently leases and deeds. ...

Introduction

Switching the United States’ current income tax system would benefit the country as a whole. Therefore, variations of the flat tax that are proposed, some of which set a percentage on income while others set a percentage on sales tax. Those arguing in favour of such tax reforms contend that it will eliminate the complexity of our current system and the loopholes. This will contribute towards boosting of the economy. One such proposal, on which a number of books have been written, is called Fairtax. This is a flat rate sales tax only on new items. For example, if someone were to buy a used ...

Accounting 101

Deciding on Accounting Major If I had to decide on the accounting major to pursue, I would choose to be a forensic accountant. This major of accounting deals with the investigation of potential frauds within a company, or prevention of fraudulent activities from occurring. Forensic accountants are also commonly known as fraud investigators, investigative accountants, forensic auditors, or fraud auditors. Of all possible accounting majors, this one attracts me the most due to a number of reasons, including the history of this major, the variety of potential employment places, the nature of the job itself, and the knowledge and skills commonly ...

Differences between National and International NGOs -

A Case Study of the US, Bahrain and India (Author name) (Supervisor name)

References

1 Introduction Non-Governmental Organizations or NGOs have become influential actors of societal development and change on a national as well as international scale. Beginning as non-governmental consultants to the United Nations, the number of NGOs across the world has witnessed exponential growth since the 1980s. Although most people understand what an NGO is - the name itself makes it very clear that these are organizations that are not government run – there is little consensus on what may be described as key characteristics of an ...

Individual Income Tax (North Carolina)

Individual Income Tax (North Carolina) Personal income tax or individual income tax refers to the levied tax on personal income. Here, individual refers to a person, non-juristic body of person, an ordinary person or an individual estate. For an individual to be liable for personal income tax, one has to compute file tax returns, compute tax liability as well as pay the indicated tax as according to the calendar of the year. The individual tax income differs in different states with each state having its own rights of running the tax provided by its residents. This research would look ...

Introduction

The task of this report requires the development and analysis of a counterintelligence activity, which specializes in the involvement of drugs, pertaining to an operation conducted by the Federal Bureau of Investigation (FBI). A plethora of counterintelligence sectors exist including matters involving illegal drug activities, terrorism, child pornography rings, money laundering, Internet scams, corporate security, and more. In general, counterintelligence competes with these aforementioned areas sometimes in ways that overlap. For example, an Internet scam may involve theft of consumer credit card information – as well as running illegal or non-existent gambling websites. The chosen case study to be developed concerns ...

Executive summary

The Affordable Care Act (ACA) addresses the challenges facing the health industry. The government has been implementing the provisions in incremental stages since 2010 and more changes are still underway. This report discusses the impact that this act has on indoor tanning services by analyzing the indoor tanning services tax, health insurance coverage duty on employers and the additional Medicare tax. Firstly, the indoor services tax applies to businesses offering tanning services as their predominant activity. However, the law provides tax exemptions to providers such as phototherapy services, qualified physical fitness facilities, spray-on tanning services and those selling tanning ...

- In Sec 1031 of Internal Revenue Code, what type of stocks are not included as stock for purposes of Sec 1031 like kind exchanges? The Internal Revenue Code subsection 1031 stipulates that you have to pay tax whenever you sell an investment property or business and gain from it. Tax is paid on the gain made at the time of sale. Under this section, a real property owner can decide to reinvest the proceeds from the sell in ownership of a like-kind property and defer the capital gain taxes. However, certain types of stocks are specifically excluded from Sec. ...

Introduction:

This paper is a case study about a crime that occurred at Old Annapolis Road, Columbia on 11th March 2000 at 0030 hours. The nature of the crime was homicide and the victim of the crime was a teenager by the names Ashley Nicole Smith. She was found brutally murdered by stabbing in a pool of her own blood in a wooden area that was located just behind 9170 Old Annapolis Road. The suspected murderers of the teen were Scott Roy Jones and Frederick James Johnson. This paper analyses how investigations were conducted from the time her body was found. It also discusses the ...

Tax Research Project 2

Introduction: In 1976, Congress amended the tax law to include Section 280A (Lawyer, 1985) in the Internal Revenue Code. Congress’ reason for the amendment was due to concerns that people were renting out their vacation homes so that they could deduct personal expenses that would not, under normal circumstances, be deductible (Lawyer, 1985). Section 280A required vacation home owners to assign expenses connected with the vacation home either to personal use or rental use. Congress apparently hoped that Section 280A would limit or control the business deductibles for expenses sustained on a vacation home during the tax year when ...

The terms ‘white collar crime’ and ‘tax evasion’ have precariously vacillated from the perception or classification of bonafide crime, or non-criminal acts. The slippery slope of tax evasion in relation to white collar crime sustains serious implications, historically and to the present. According to expert sources at Cornell University Law School, the definition of white collar crime is explained by giving an overview of an early incident in 1939, when sociologist Edwin Sutherland “coined” the phrase. Sutherland defined white collar crime as an act involving “crime committed by a person” who is normally tremendously respected in their line of occupation, ...

Introduction

NGO or non-governmental organizations are legally formed organizations managed independently by legal people without any interference of government. Any NGO funded partially or fully by government in order to maintain its non-governmental status prevents government representatives from taking membership in the organization (NGO 2010). NGOs generally serve the social purpose that might or might not have political aspects. NGOs are task oriented and managed by people sharing the same interest and goals. NGOs serve wide-ranging purposes attracting the attention of both citizens and governments to issues involving health care, human rights, environment and so on. The World Bank has ...

What are the Types of Ethical Predicaments Encountered in Public Personnel Administration?

Types of Ethical Predicaments Encountered in Public Personnel Administration 3 Common Ethical Dilemmas 3 The Context of Ethics 4 Administrative Discretion 5 Constitutional Prerequisite 6 Ethical Predicaments in Administrative Discretion 6 Corruption 7 Ethical Predicaments in Corruption 8 Other Types of Ethical Predicaments 9 Nepotism 9 Information Leaks 10 Public Accountability 10 Policy Dilemmas 10 Discussion 11 Conclusion 12

References 13

Types of Ethical Predicaments Encountered in Public Personnel Administration The success and reputation of governance depends upon the functionalities and conduct of the public administrators. ...

Millions of uninsured Americans will be provided with more rights and protections as well as wider access to affordable quality healthcare through the healthcare reform program known as The Affordable Care Act or ObamaCare. Signed into law on March 23, 2010, the Patient Protection and Affordable Care Act law requires that by 2014, all Americans must obtain health insurance which can be purchased through the State‘s Health Insurance Exchange Marketplace. It requires all Americans to purchase a private health care plan, get an exemption or pay 1% - 2.5% tax penalty of their taxable income. Those who cannot afford ...

Introduction

In the United States, and in other developed countries, healthcare is treated more like a necessity than a benefit, contrary to the way how most developing countries prioritize the provision for healthcare and other health and wellness-related services, wherein it is perceived more like a luxury. This is one of the main reasons why there are a lot of thriving health and medical insurance companies in the U.S. and other developed countries. The citizens in those places are willing to pay a premium just to get the best healthcare services for themselves and their family members, who basically act as dependents in a family health ...

- Is Steve's un-reimbursed commuting expenses an allowable deduction on his personal tax return if he is assigned to be a volunteer usher for the Church's Saturday or Sunday services? If Steve is assigned to be a volunteer in the church on both Saturdays and Sundays, his tax position regarding the un-reimbursed commuter expenses can be explained as follows: According to code 162(a), the un-reimbursed commuter expenses remain unallowable for tax purposes because of the following reasons: Such expenses are not incurred for a profit gain. Steve is not in any profitable business so as to be able to claim ...

ACCOUNTING

Memorandum RE: Zavala, Julio and Clara This memo includes a brief summary of the Julio Zavala information pertaining to tax law, a brief discussion of the tax issues that arise and examples of court cases that are likely to have an influence on the tax status of Zavala, his wife and son. Julio Zavala is married (Clara) and they have one adult son (Robin). Due to medical issues Robin lives at home with his parents. Zavala was able to retire from his day job (9am to 5pm) because he has enough money to do so. He has enough ...

RE: Mr. and Mrs. Julio Zavala I have reviewed the memo regarding the requests of Julio and Clara Zavala regarding their taxes. The couple is married. He has enough money at his disposal that he was able to quit his 9 to 5 job and travel extensively. Here is a summary of the four main tax issues according to the information you provided. The first issue to consider is whether or not Julio Zavala’s expenditures can be considered as tax deductions. These trips were combination of work objectives and leisure activities to entertain his potential clients who are ...

1. The fact that George is an active participant in his companies 401(k) and contributes 5% of his salary his contributions are fully deductible. In the case of Jane, her contributions are not fully deductible for the year 2012. This is mainly because she is going to make her return after the tax day deadline of April 15. According to code §6151 (c), the time and place for making returns is strictly set by law. The code states that if a date has been fixed for returns then it is considered the final date for all returns to ...

Security Policy

Creation and implementation of information security policies should be a top priority for any firm, organization or a federal agency that depends on integrated information systems and networks to perform it day-to-day activities. It is most important for government agencies to address information security issues in order to gain the public trust. An improvement in information technology, communication systems, and the use of the internet is a necessary drive for government agencies to change the procedures of carrying out its business and execution of its functions to the public. Without proper policies and security measures to safeguard sensitive information, the agencies run a ...

Ethics in Tax Practice

For an individual professional to be termed as ethical, he has to conform to professional standards of a certain group, or profession. Therefore, tax practitioners need to comply with the tax legal requirements, as well as, American Institute of Certified Public Accountants (AICPA) rules, for them to be termed as ethical. The legal requirements, together with non-compliance penalties are found in Circular 230 in the Treasury department. They are also found in the Internal Revenue Code (1986). This paper discusses the legal tax requirements for the tax practitioners. The law is believed to be complex as many people find it ...

I have reviewed your memo regarding our client Howdy Brewster which describes his business activities and the recent events which may impact his 2011 Federal Tax Return. Here is a review of the factual information about Brewster which pertains to the income tax questions. His business is an eight hundred fifty acre farm and dairy operation. About 150 Holstein milk cows are part of the dairy operation. Approximately 150 Black Angus steers are raised to sell. Brewster has one part-time employee. He employs his two teen-age sons for the daily farm work. The land has been in the family for ...

I have reviewed your memo regarding our client Howdy Brewster describing his business activities and the recent events which have occurred that could have an impact on his 2011 tax returns. His business is a farm and dairy operation on 850 acres of land. The land has been in the family for close to 125 years. There are three existing houses on his property.

Mr. Brewster recently signed a contract with Aztec Oil and Gas Pipeline to allow the company to lease a portion of his land in order to run a pipeline; Aztec will need access to maintain the pipeline over its ...

Introduction: The present literature attempts to study the need for the adoption of IFRS as global accounting standards and its impact on the current tax planning strategies followed in the United States. What is IFRS: To begin with it becomes inevitable to develop a basic understanding of what exactly does the term IFRS convey. International Financial Reporting Standards (IFRS) was formed by International Accounting Standards Board with an intention to serve the growing needs of public companies on a global platform to prepare their financial statements according to a global standard in order to ensure transparency and uniformity in the projection ...