Advanced Federal Tax solutions
Research Problem 1. Locate the following cited items and give a brief description of the topic or opinion in the item:
a. § 59A(a).
Internal Revenue Code Section 59A which refers to imposition of environmental tax in the case of a corporation, there is imposed a tax equal to 0.12 percent of the excess of the modified alternative minimum taxable income of such corporation for the taxable year, over $2,000,000.
b. Reg. § 1.6166(a)(8)(D)(i).
Treasury regulation which refers to the 10-year estate tax installment payment provision for the purpose of the 5-year deferral, the holding company is any corporation holding stock in another company.
c. Ltr.Rul. 200134022.
IRS Letter Rulings 200134022 deals with tax imposed on certain built-in gains (for corporations electing S status after 12/31/86). The 10-year built-in gain recognition period for Corporation will continue to be treated as commencing on the effective date of Corporation’s election to be an S corporation. After switching to c corporation (real estate investment trust), the net unrealized built-in-gain of Corporation will continue to be calculated based on the fair market value and adjusted basis of Corporation’s assets.
d. FSA 200005006.
Field Service Advice Memorandum,FSA 200005006, deals with an application of section 83, the transfer of the options to ex-wife pursuant to the divorce decree (because it is a disposition of the options) resulted in compensation income to husband that was includible in his gross income at the time of the transfer. Because the transfer was an arm's length transaction, husband had no compensation income under section 83 when ex-wife exercised the options.
Research Problem 2. Determine the validity of the following items:
a. Rev.Rul. 67–225, 1967–2 C.B. 238.
Revoked by Rev. Rul. 73-302, 1973-2 C.B.220.
b. Walter F. O’Brien, 38 T.C. 707 (1962).
Subsequent Developments and affirmed by 63-2 ustc ¶9633, 319 F2d 532, aff'd TC.
c. Rev.Proc. 99–77, 1999–1 C.B.
a. § 59A(a).
Internal Revenue Code Section 59A which refers to imposition of environmental tax in the case of a corporation, there is imposed a tax equal to 0.12 percent of the excess of the modified alternative minimum taxable income of such corporation for the taxable year, over $2,000,000.
b. Reg. § 1.6166(a)(8)(D)(i).
Treasury regulation which refers to the 10-year estate tax installment payment provision for the purpose of the 5-year deferral, the holding company is any corporation holding stock in another company.
c. Ltr.Rul. 200134022.
IRS Letter Rulings 200134022 deals with tax imposed on certain built-in gains (for corporations electing S status after 12/31/86). The 10-year built-in gain recognition period for Corporation will continue to be treated as commencing on the effective date of Corporation’s election to be an S corporation. After switching to c corporation (real estate investment trust), the net unrealized built-in-gain of Corporation will continue to be calculated based on the fair market value and adjusted basis of Corporation’s assets.
d. FSA 200005006.
Field Service Advice Memorandum,FSA 200005006, deals with an application of section 83, the transfer of the options to ex-wife pursuant to the divorce decree (because it is a disposition of the options) resulted in compensation income to husband that was includible in his gross income at the time of the transfer. Because the transfer was an arm's length transaction, husband had no compensation income under section 83 when ex-wife exercised the options.
Research Problem 2. Determine the validity of the following items:
a. Rev.Rul. 67–225, 1967–2 C.B. 238.
Revoked by Rev. Rul. 73-302, 1973-2 C.B.220.
b. Walter F. O’Brien, 38 T.C. 707 (1962).
Subsequent Developments and affirmed by 63-2 ustc ¶9633, 319 F2d 532, aff'd TC.
c. Rev.Proc. 99–77, 1999–1 C.B.