Tax Research

Topics: Taxation in the United States, Tax, Internal Revenue Service Pages: 14 (7114 words) Published: September 18, 2014


Tax Research Exercise 1

1) 147(c)(2)(C)(iii)Insolvent farmer.—For purposes of clause (i), farmland which was previously owned by the individual and was disposed of while such individual was insolvent shall be disregarded if section 108 applied to indebtedness with respect to such farmland.

2) Federal Tax Regulations, Regulation, §1.351-1., Internal Revenue Service, Transfer to corporation controlled by transferor Click to open document in a browser

Reg. § 1.351-1 does not reflect P.L. 96–589, P.L. 100-647 or P.L. 101-239.

(a)
(1)   Section 351(a) provides, in general, for the nonrecognition of gain or loss upon the transfer by one or more persons of property to a corporation solely in exchange for stock or securities in such corporation if, immediately after the exchange, such person or persons are in control of the corporation to which the property was transferred. As used in section 351, the phrase "one or more persons" includes individuals, trusts, estates, partnerships, associations, companies, or corporations (see section 7701(a)(1)). To be in control of the transferee corporation, such person or persons must own immediately after the transfer stock possessing at least 80 percent of the total combined voting power of all classes of stock entitled to vote and at least 80 per cent of the total number of shares of all other classes of stock of such corporation (see section 368(c)). In determining control under this section, the fact that any corporate transferor distributes part or all of the stock which it receives in the exchange to its shareholders shall not be taken into account. The phrase "immediately after the exchange" does not necessarily require simultaneous exchanges by two or more persons, but comprehends a situation where the rights of the parties have been previously defined and the execution of the agreement proceeds with an expedition consistent with orderly procedure. For purposes of this section—  

(i)   stock or securities issued for services rendered or to be rendered to or for the benefit of the issuing corporation will not be treated as having been issued in return for property, and (ii)   stock or securities issued for property which is of relatively small value in comparison to the value of the stock and securities already owned (or to be received for services) by the person who transferred such property, shall not be treated as having been issued in return for property if the primary purpose of the transfer is to qualify under this section the exchanges of property by other persons transferring property. For the purpose of section 351, stock rights or stock warrants are not included in the term "stock or securities."

3) Revenue Rulings, Rev. Rul. 2004-55, Internal Revenue Service, (Jun. 9, 2004) Click to open document in a browser
Rev. Rul. 2004-55, I.R.B. 2004-26, June 9, 2004.
[ Code Sec. 104]
Disability benefits: Long-term disability: Gross income.–
Long-term or short-term disability benefits received by an employee who has irrevocable elected, prior to the beginning of the plan year, to have the coverage paid by the employer on an after-tax basis for the plan year in which the employee becomes disabled, would be attributable solely to after-tax employee contributions. Thus, the benefits would be excludable from the employee's gross income under Code Sec. 104(a)(3). Back reference: ¶6662.26. [ Code Sec. 105]

Disability benefits: Long-term disability: Gross income.–
Long-term or short-term disability benefits received by an employee whose coverage was paid by the employer on a pre-tax basis for the plan year in which the employee became disabled would be attributable solely to pre-tax employer contributions. Thus, the benefits would be includible in the employee's gross income under Code Sec. 105(a). Back reference: ¶6702.52. ISSUE

Under the Amended Plan described below, are long-term disability benefits received by an employee who becomes disabled excludable...

References: 4. Ross Pierce prepared the original letter calling a meeting held in Sacramento, California on September 3, 1907, which meeting was the beginning of the California Land Title Association.
9. Plaintiff is a California corporation formed March 31, 1925 and has its principal office in Placerville, El Dorado County, California. The company acquired the assets of the Pierce-Bosquit Abstract and Title Co. for Nevada and El Dorado Counties.
U.S. Tax Court, Docket No. 6886-80, 43 TCM 1481, TC Memo. 1982-292, Filed May 26, 1982 [Appealable, barring stipulation to the contrary, to CA-6.—CCH]
[Code Sec
11) U.S. Master Tax Guide (2013), 1195. Hobby Expenses and Losses
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12) Standard Federal Tax Reporter (2013), 14,417.043, Substantiation Requirements and Per Diem Rates: Standard Mileage Rate Allowances for Automobiles: Standard mileage rate allowances for automobiles, in general
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