ACCT 429 Week 7 Research Project
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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