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Chapter 02 Tax Compliance, the IRS, and Tax Authorities

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Question;97.;For the;following taxpayers, please recommend the most advantageous trial level;court(s) to litigate a tax issue with the IRS.;a. Joe is litigating;a tax issue with the IRS that is considered a question of fact (i.e., the;answers depends on the facts of the case). There is not a lot of authority on;point for this case but Joe has a very appealing story to justify his;position that is likely to be viewed sympathetically by his peers.;b. The Circuit Court;of Appeals for the Federal Circuit recently issued an opinion that is very;favorable to the issue that Jesse plans to litigate with the IRS.;c. The Circuit Court;of Appeals for the Federal Circuit recently issued an opinion that is not;favorable to the issue that Hank plans to litigate with the IRS.;d. The 7th;Circuit (where Elizabeth resides) recently issued an opinion that is very;favorable to the issue that Elizabeth plans to litigate with the IRS.;98.;A client has;recently learned of a recently proposed tax bill that would increase the tax;rates on investment gains by 5 percent. The President does not support this;increase. Please describe for your client the process by which new tax;legislation is created and how the President's disapproval may influence the;enactment of the bill.;99.;Chris and;Chuck were recently debating whether the Internal Revenue Code is;logical." Chris offers that she has briefly reviewed the Code and;could hardly understand its organizational structure, if there is one. Please;describe the basic organization of the code and how understanding its;organization may be especially beneficial to the tax researcher.

 

Paper#55169 | Written in 18-Jul-2015

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