BRADLEY UNIVERSITY ATG 477 FEDERAL TAXES I COLEEN S. TROUTMAN ASSOCIATE PROFESSOR, CPA, Ph.D. NAME: ____________________ Instructions: 1) 2) 3) 4) 5) 6) 7) A maximum of two hours are allowed to complete this examination. This is a closed book examination. Only simple non-programmable calculators will be allowed. The exam consists of 50 multiple choice questions. Mark your answer clearly on the Scantron. Notes and other work will not be considered in determining a grade. This Final Examination is based on the textbook: Concepts in Federal Taxation, by Murphy & Higgins, 2008 Edition, published by Thompson South-Western. Chapter One Two Three Four Five Six Seven Eight Nine Ten Eleven Twelve Fourteen Title Federal Income Taxation—An Overview Income Tax Concepts Income Sources Income Exclusions Introduction to Business Expenses Business Expenses Losses—Deductions and Limitations Taxation of Individuals Acquisitions of Property Cost Recovery on Property: Depreciation, Depletion, and Amortization Property Dispositions Nonrecognition Transactions Choice of Business Entity—Operations and Distributions 8) If you have questions regarding this examination please refer to the TAC student guide for direction about whom to contact. 9) Your final grade for ATG 477 will be available after 30-JUNE-2008. 10) The question package (examination) and scantron must be returned at the end of the examination period. ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 1 OF 18 1. Megan is a single individual. In the current year, she receives $10,000 of tax-exempt income in addition to her salary and other investment income. Megan's tax return showed the following information: Gross income Taxable income Total tax $100,000 $ 80,000 $ 16,900 Which of the following statements concerning Megan's tax rates is (are) correct? I. Megan's average tax rate is 18.8%. II. Megan's average tax rate is 21.1%. III. Megan's effective tax rate is 18.8%. IV. Megan's effective tax rate is 15.4%. a. I and III are correct. b. I and IV are correct. c. II and III are correct. d. II and IV are correct. e. Only II is correct. 2. Indicate which of the following statements concerning the following tax rate structures is/are correct. When Income Total Tax Equals Equals Structure #1 10,000 600 100,000 5,000 Structure #2 15,000 450 75,000 4,500 Structure #3 13,000 975 86,000 6,450 I. Tax Structure #1 is progressive. II. Tax Structure #2 is proportional. III. Tax Structure #2 is progressive. IV. Tax Structure #3 is regressive. a. Only I is correct. b. Only III is correct. c. I and II are correct. d. II and IV are correct. e. I, II, and IV are correct. 3. Which of the following statements is true concerning a CPA's responsibility when the CPA uses taxpayer estimates in preparing a tax return? a. Tax preparation requires the CPA to exercise judgment but prohibits the CPA's use of estimates and approximations. b. Use of taxpayer estimates in a tax return is prohibited unless they are specifically disclosed by the CPA. c. The CPA may prepare tax returns involving the use of taxpayer estimates even if it is practical to obtain exact data. d. When all facts relating to a transaction are not accurately known because records are missing, reasonable estimates made by the taxpayer of the missing data may be used by the CPA. 4. Debra sells a business-use warehouse to her wholly owned corporation. Debra realizes a loss of $48,000 on the sale. (Sales price, $102,000, less adjusted basis, $150,000). Tax law does not permit Debra a deduction for the $48,000 loss. Which of the following help(s) explain this tax result? I. Arm's-length Transaction Concept. II. Pay-As-You-Go Concept. III. Related Party Provisions. IV. Business Purpose Concept. a. Only I is correct. b. Only II is correct. c. III and IV are correct. d. I and III are correct. e. I, II, III, and IV are correct. 5. In which of the following will the Constructive Receipt Doctrine require reporting income in Year 1? I. Cornell's December Year 1 salary check is withheld until January 15, Year 2, because the employer does not have sufficient cash to cover its December payroll. II. Donnie is an employee of Holt Corporation. The corporation regularly mails payroll checks to employees to arrive on, or before the last day of each month. Donnie's check arrives in the mail at his house on December 31, Year 1. However, Donnie was vacationing in Cancun and did not return until January 8, Year 2. Donnie deposited the check into his account the next day. III. In December Year 1, Carl signs a contract to play basketball for the Rhythms. He receives a signing bonus of $5,000,000 to be paid over 5 years beginning in Year 2. His regular salary of ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 2 OF 18 $300,000 will be paid monthly during the season that begins in Year 2. a. I, II, and III are correct. b. II and III are correct. c. I and II are correct. d. Only II is correct. e. Only III is correct.} 6. Steve sells a parcel of investment real estate to Oswald for $600,000 in Year 1. Steve will receive $200,000 annually, plus interest at 8%, from Year 2 through Year 4. Steve will recognize no gross income on this sale in Year 1. Which of the following requires this treatment? a. Capital Recovery Concept. b. All-inclusive Income Concept. c. Ability -To-Pay Concept. d. Claim of Right Doctrine. e. Wherewithal -to-Pay Concept. 7. Bijou Bagels is an S corporation that reports an operating income of $60,000 in the current year. Bijou also has a $20,000 Section 1231 gain from the sale of a building and $10,000 in nondeductible expenses. Bernice owns 20% of Bijou and receives a $5,000 distribution from Bijou during the current year. Liabilities of Bijou decreased by $30,000 during the year. Bernice's basis will increase (decrease) by: a. $ 3,000 b. $ 9,000 c. $11,000 d. $16,000 8. Bronco Corporation realizes $270,000 from sales during the current year. Bronco also receives $20,000 of dividends from a 2% owned corporation. Operating expenses total $275,000. Bronco's taxable income (loss) is a. $(19,000) b. $ (5,000) c. $ 1,000 d. $ 4,500 e. $15,000 9. Chowder Company, a partnership, has an operating loss of $400,000 for the current year. Hank owns a 40% interest in the company and is a material participant. At the beginning of the year, Hank's adjusted basis in the partnership is $30,000. During the current year, Chowder distributes $60,000 cash and borrows $100,000 with a recourse note. How much of the loss can Hank deduct on his current-year income tax return? a. $ - 0 b. $ 6,000 c. $ 46,000 d. $106,000 e. $160,000 10. Cancun Corp. has gross income of $230,000 and taxable income of $50,000. The company did not include any special deductions in the calculation of taxable income. While reviewing the tax return, Cancun's accountant finds $20,000 of charitable contributions improperly classified as advertising and promotion expense. He sends the return back to the tax department for correction. What is Cancun's corrected taxable income? a. $35,000 b. $55,000 c. $57,000 d. $63,000 e. $65,000 11. Penelope purchased an annuity contract that cost $45,000. The contract will pay Penelope $600 per month for 10 years after she reaches age 62. During the current year, Penelope turns 62 and receives 4 payments under the contract. Penelope's gross income from the annuity payments is: a. $ 900 b. $1,500 c. $2,250 d. $2,400 12. Which of the following statements is/are correct? I. Maria receives $300 from her employer in recognition of her production unit's safety record ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 3 OF 18 at the company's annual meeting. Maria is not taxed on the $300. II. Reggie opens a savings account at Mid Financial Savings and Loan. For opening the account he receives a microwave worth $200. On December 31, his account is credited for $300 of interest income. Reggie must report $500 of income. III. Sue was chosen Miss City. She won both the bathing suit and the talent contests. She donated her $1,000 cash award to a qualifying charitable organization established to carry on cancer research. Sue must report $1,000 of income. a. Statements I, II, and III are correct. b. Only statements I, and II are correct. c. Only statements II and III are correct d. No statement is correct. 13. Marvin and Stacy are retired. During the current year, they receive $10,000 in Social Security benefits. They have $95,000 of other taxable gross income and receive $23,000 of municipal bond interest. The taxable portion of the $10,000 Social Security payment is: a. $ -0b. $ 5,000 c. $ 8,500 d. $10,000 14. Given below are Bart's capital gains and losses for two consecutive years. What is the effect of the capital gains and losses on Bart's taxable income for each year? Short-term capital gain Long-term capital gain Short-term capital loss Long-term capital loss a. b. c. d. e. First Year $(9,000) $ 3,000 $(3,000) $(3,000) $(3,000) First Year Second Year $12,000 11,000 (9,000) (23,000) $0 16,000 (2,000) (5,000) Second Year $ 9,000 $ 1,000 $ 3,000 $(3,000) $ -0- 15. Which of the following payments received on December 31, Year 1, would be recognized by a cash basis taxpayer in Year 1, but would not be recognized in Year 1 by an accrual basis taxpayer? I. Checks received from customers for services rendered during November and December Year 1. The checks are deposited in the bank account on January 4, Year 2. II. Checks received from tenants for rent for Year 2. The checks are received in the morning mail and deposited in the bank account on December 31, Year 1. III. A check received from a customer for a service contract. The services under the contract are to be rendered over 24 months, beginning in January Year 2. The check is deposited in the bank account on January 4, Year 2. a. Only statement I is correct. b. Only statements I and II are correct c. Only statements II and III are correct. d. Only statement II is correct e. Only statement III is correct. 16. Charlie is a building contractor who builds 25-30 homes a year. Janet is a real estate broker who sells all of Charlie's homes. Janet has recently referred a couple to Charlie who wanted him to build a $500,000 home for them. Knowing that Janet and her husband enjoy skiing, he bought her a nice pair of skis and boots. I. The "gift" has a compensatory element. II. The skis meet the income tax definition of a gift. III. Substance-over-form applies to this situation. IV. Janet recognizes no gross income from the receipt of the skis. a. Only I is correct. b. Only IV is correct. c. I and III are correct. d. II and IV are correct. e. II, III, and IV are correct. 17. Which of the following qualify as replacement property under the involuntary conversion rules? ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 4 OF 18 I. Mayfield Ice Cream Company's production plant is destroyed by a hurricane. The insurance proceeds are used to replace the plant with a refrigerated storage container. II.Yummy Yogurt Company's warehouse for storing its yogurt curds is condemned by the port authority. The warehouse will be replaced with a new office building in a neighboring community. III. Yummy Yogurt Company's other warehouse, which was fully leased to another company, is destroyed by a tornado. The warehouse will be replaced with a rental office building adjacent to the company's new office building and will be leased to various tenants. a. Only statement I is correct b. Only statement II is correct c. Only statement III is correct. d. Statements II and III are correct e. Statements I, II, and III are correct. 18. Katherine, age 38, is an employee of National Tools, Inc. Her annual salary is $50,000. After considering the following list of benefits provided Katherine, determine her gross income for the year. •Katherine has $2,000 of her salary withheld and paid into the company's qualified pension plan. The company matches the contribution at the rate of $.50 for each $1.00 paid in. •Group-term life insurance policy at twice her annual salary paid by the company. Premium cost is $1.08 per $1,000 of coverage. •Health and accident insurance policy costing $1,500 paid by the company. •Katherine elects to have $1,800 of her salary paid into a flexible benefits plan to cover childcare costs. She incurs $2,100 of childcare costs during the year. a. $44,700 b. $44,754 c. $46,254 d. $48,054 e. $50,000 19. Jacob is experiencing cash flow problems during the current year. Rather than foreclose on an $80,000 loan, his bank agrees to reduce the debt to $50,000. Prior to the debt reduction, Jacob's total assets were $490,000 and his total liabilities were $500,000. How much income must Jacob recognize from the reduction of his bank loan? a. $30,000 b. $20,000 c. $10,000 d. - 0 20. Charlotte traveled to Annapolis to attend a three-day business conference. After her meetings concluded, she stays 2 additional days sightseeing and enjoying the crabcakes. Charlotte's airfare is $400 and pays $110 per night for lodging, $60 a day for meals, and $20 a day for incidentals. How much of Charlotte's costs can be deducted as a business expense? a. $ - 0 b. $ 400 c. $ 880 d. $ 970 e. $1,200 21. Which of the following statements is/are correct? I. Terry's divorce decree provides that his ex-wife is to pay him alimony of $500 per month until their son reaches age 18 or dies, at which time the payment will be reduced to $200. Terry must recognize $200 of alimony income each month. II. Jerry is the manager of Northgate apartments. He is required to live in an apartment in the complex that normally rents for $600 per month. Jerry must recognize $600 per month as income from his management job. III. Maria is retired. Her only sources of income are her $6,000 pension and $8,000 of Social Security benefits. Maria must include $6,000 pension in her gross income. IV. Helen receives a scholarship from the music department that pays her $300 per month. As a condition of receiving the scholarship, Helen must work as a lab assistant 15 hours per week. Helen's total direct education costs are $9,000. Helen excludes the $300 per month scholarship. a. I and IV are correct. b. II and III are correct. c. II and IV are correct. ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 5 OF 18 d. I and III are correct. e. None of the above. 22. Melissa owns 40,000 shares of Wilkerson Corporation common stock that cost $99,000 four years ago. During the current year, Wilkerson distributes a 10% stock dividend to shareholders. Melissa receives 4,000 new shares when the market value of the stock is $9 per share. Later in the year, the corporation distributes a cash dividend of $0.50 per share. What are the tax effects of these distributions to Melissa? I. The $22,000 cash dividend is included in gross income. II. The $36,000 stock dividend is included in gross income. III. Only $20,000 of the cash dividend is included in gross income. IV. At the end of the year, the per share basis in the stock is $2.25. a. I and II are correct. b. III and IV are correct. c. I and IV are correct. d. Only IV is correct. e. Only I is correct 23. Ben drives a taxi on weekends. In maximizing the amount of fares he earns, he occasionally gets tickets for speeding. Ben figures that as long as he keeps his traffic violations under $100 over a weekend, he can more than offset those costs with additional fares. What is/are the tax effect(s) of Ben's speeding ticket costs? a. The costs are deductible because they are ordinary and necessary expenses directly related to the business. b. The costs are deductible because they have a business purpose and the business is not illegal. c. The costs are not deductible because the business activity is illegal. d. The costs are not deductible because they are due to violations of law. e. None of the above. 24. Which of the following payments are deductible? I. Wilcox paid $1,500 to a fund to finance the campaign of an incumbent county commissioner who is a supporter of the construction industry. II. Wilcox is in the construction business. In January, he sends his chief financial officer to Washington, D.C., to monitor current legislation affecting the real estate industry. Expenses totaled $2,100. III. In March, Wilcox personally travels to Washington, D.C., to testify before the banking subcommittee on the effects of proposed legislation on the construction industry. Expenses totaled $2,300. a. Only I is correct. b. Only II is correct. c. Only III is correct. d. I and III are correct. e. I and II are correct. 25. T's employer provides an office for her in its downtown headquarters. I. Terry maintains an office in her home that she uses exclusively to conduct work related to her rental properties. Even though the rental activities may be considered a business, no deduction can be allowed because Terry’s principal business is that of being an employee and its primary location is downtown. II. T regularly meets with clients of her employer's business in her home office which is exclusively used for such purpose. T is entitled to the home office deduction without further inquiry. III. T maintains a home office that is exclusively used on a regular basis to conduct work regarding her investment portfolio. No deduction is allowed. a. Only I is correct. b. Only II is correct. c. Only III is correct. d. I and III are correct. e. I and II are correct. 26. The following persons probably would be allowed a business expense deduction for the educational costs. I. Marta, who is an engineer, takes courses towards an MBA in hopes she will be promoted to a management position. ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 6 OF 18 II. Terry, a nurse, who, after five years absence from the work force, takes a refresher course before looking for a job. III. Carlos, a teacher, takes educational courses in the summer to maintain his teaching certificate. a. Only I is correct. b. Only II is correct. c. Only III is correct. d. I and III are correct. e. I and II are correct. 27. D owns and operates her own real estate business. She loves to entertain. I. D takes her new neighbor to the ball game. The cost of the tickets is a qualifying entertainment expense assuming D's entertainment expense creates goodwill that may lead the individual to become D's client if and when he decides to sell his house. II. D takes a prospective client to the theater. Unless the taxpayer can prove otherwise, the IRS presumes the expense is not deductible because the nature of the event is not conducive to a business discussion. III. D presents a proposal for a new real estate venture to a client during the afternoon. Following the conclusion of the meeting, D takes the client to dinner. The cost of the dinner is a qualifying entertainment expense even if business is not discussed during dinner. a. Only I is correct. b. Only II is correct. c. Only III is correct. d. I and III are correct. e. II and III are correct. 28. Susan is the sole owner of a 35-unit apartment complex. She spends 950 hours a year managing the property. In addition, she works part-time for a mortgage company. She spends 1,150 hours a year as a bookkeeper at the mortgage company. The apartment complex generated a loss of $32,000, and Susan's adjusted gross income for the current year, before considering the apartment complex, is $48,000. How much of the loss can Susan deduct? a. $ - 0 b. $14,476 c. $16,727 d. $25,000 e. $32,000 29. Amy borrowed $25,000 for her business from a local bank two years ago. To increase her deductions, she pays December interest of $400 and prepays January and February interest totaling $800 on December 30, of the current year. The maturity date of the note is November 30, next year. How much of the interest that she paid in December is deductible in the current year? I. If she is a cash-basis taxpayer, Amy's interest deduction is $1,200. II. If she is an accrual-basis taxpayer, Amy's interest deduction is $400. a. Only statement I is correct. b. Only statement II is correct. c. Both statements are correct. d. Neither statement is correct. 30. Electronic City sells TV's, VCR's, DVD's, and various other electronic products. With each of its products, Electronic City offers customers the option of purchasing a repair contract. Under the contracts, Electronic City will repair any product it sold during the term of the contract. Electronic City estimates that repair costs related to this year's sales will be $39,000. During the current year, Electronic City incurs repair costs of $37,000 related to prior year's contracts and $4,000 on contracts sold this year. I. If Electronic City accounts for the contracts using the accrual method of accounting, its repair cost deduction is $39,000. II. If Electronic City accounts for the contracts using the cash method of accounting, its repair cost deduction is $41,000. a. Only statement I is correct. b. Only statement II is correct. c. Both statements are correct. d. Neither statement is correct. 31. Gary Deans, proprietor of Gary's Easy Loan Company, loaned Jessie $4,000 on December 1, Year 1. The loan is to be repaid on December 1, ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 7 OF 18 Year 2. On July 10, Year 2, Gary learns that Jessie has filed for personal bankruptcy and that nonsecured creditors will receive only $0.60 on the dollar. Gary actually receives nothing until February 24, Year 3. On that date, Gary receives a check for $1,000 from Jessie's bankruptcy proceedings in final settlement of the loan. How should Gary account for the loan to Jessie? a. $1,600 short-term capital loss in Year 2; and $1,400 short-term capital loss in Year 3. b. $3,000 ordinary loss in Year 3. c. $2,400 ordinary loss in Year 2. d. $1,600 ordinary loss in Year 2; and $1,400 ordinary loss in Year 3. e. $3,000 short-term capital loss in Year 3. 32. Which of the following expenses is not deductible for AGI? a. Alimony paid. b. Contributions to an IRA. c. Moving expenses. d. Expenses related to stock market investment activity. e. All are deductible for AGI. 33. Results for a single taxable entity for the current year: Active Portfolio Passive Income Income Income Income(Loss) $30,000 $6,000 $(55,000) I. If the taxpayer is a closely held corporation, taxable income from the three activities is a loss of $19,000. II. If the taxpayer is an individual and the passive income is not related to a rental real estate activity, taxable income is $36,000. a. Only statement I is correct. b. Only statement II is correct. c. Both statements are correct. d. Neither statement is correct. 34. Lisa sells some stock she purchased several years ago for $10,000 to her brother Bart for $8,000. One year later Bart sells the stock for $12,000. The tax consequences to Lisa and Bart are: Lisa Bart a. $2,000 loss $4,000 gain b. No gain or loss c. No gain or loss d. $2,000 gain e. $2,000 loss $4,000 gain $2,000 gain No gain or loss $2,000 gain 35. Willie sells the following assets and realizes the following gains (losses) during the current year: Personal auto $(5,000) Municipal bonds (7,000) Stamp collection 4,000 Furniture (6,000) ABC Common Stock (8,000) As a result of these sales, Willie's adjusted gross income will: a. Increase by $ 5,000. b. Increase by $12,000. c. Decrease by $3,000. d. Decrease by $5,000. e. None of the above are correct. 36. Arthur owns a farm, which has three separate houses. He rents out two of the houses and lives in the other house. During the current year, a tornado goes through his property causing damage to the houses. Rental House A had a fair market value of $40,000 and an adjusted basis of $20,000, but is not damaged by the tornado. A local real estate agent told Arthur that because of the tornado, property values in the area have declined 10%. Rental House B, which has an adjusted basis of $25,000, is worth $60,000 before the tornado and $20,000 after the tornado. Arthur's insurance company pays him $20,000 for the damage to Rental House B. Arthur's residence (which has an adjusted basis of $80,000) was worth $70,000 before it is totally destroyed by the tornado. Arthur's insurance company reimburses him $60,000 for the loss of his residence. I. Arthur deducts a loss of $4,000 on Rental House A. II. Arthur deducts a loss of $35,000 on Rental House B. III. Arthur's loss on his residence (before any annual limitations) is $9,900. a. Only I is correct. b. Only II is correct. ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 8 OF 18 c. Only III is correct. d. I and II are correct. e. I, II, and are correct. What amount can Paul and Anne claim as an itemized deduction for taxes on their federal income tax return for the year? 37. Maureen is single and her adjusted gross income is $25,000. In addition, she pays the following expenses during the year: Psychiatrist's fee $ 300 Hospital bill for medical services and room $1,200 Transportation to/from hospital $30 Prescription drugs $100 Over-the counter vitamins $125 Chiropractor's fees $350 Maureen pays $600 for medical insurance premiums and receives a reimbursement of $400 from the insurance company for her medical expenses. Compute her medical deduction. a. $ - 0 b. $ 275 c. $ 305 d. $1,875 e. None of the above 38. Joseph purchases a new principal residence in the current year for $285,000. He borrows $220,000 from a local mortgage company and pays loan origination fees of $1,600 and points of $2,200. During the year, Joseph pays $7,000 of interest on the loan. What is Joseph's allowable interest deduction for the year? a. $ - 0 b. $ 7,000 c. $ 8,600 d. $ 9,200 e. $10,800 39. During the current year, Paul and Anne Gardner pay the following taxes: State income tax (balance due for last year) $1,000 Estimated state income tax $2,400 Estimated federal income tax $3,250 Sales tax $600 State gift tax $500 Property tax $2,450 Real estate tax on condominium $1,100 a. $ 5,850 b. $ 6,950 c. $ 7,450 d. $10,250 e. $11,350 40. Suzanne makes the following contributions during the current year: Purchase of raffle ticket from church $ 50 Cash given to church $200 Chamber of Commerce dues $500 Stock acquired in 1997 donated to State University (Cost = $1,000; FMV = $1,800) Clothing donated to Goodwill (Cost = $800; FMV = $200) If Suzanne's gross income is $35,000, what is her allowable charitable contribution? a. $ 1,400 b. $ 1,450 c. $ 2,200 d. $ 2,250 e. $ 2,750 41. Ben is single and owns a two-bedroom home. His brother, George, moved in with Ben in January of the current year to attend the local college full-time. George is 19 years old. Ben provided $5,000 toward George's support during the year. George received a scholarship for $3,000 and earned $3,500 at a part-time job, all of which George used for his support. I. The support test is failed because George provides more than half of his own support. II. Since George is not Ben’s son, George would have to have income less than the exemption amount to qualify as a dependent. III. Ben cannot file head of household since George is not Ben’s son. IV. Ben can file head of household since George is a qualifying child. a. I, II, and III are correct b. I, II, and IV are correct c. II and IV are correct d. only IV is correct ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 9 OF 18 e. none are correct. 42. Bob receives a gift of stock from Martha on June 1 of the current year. Martha paid $12,000 for the stock several years ago. Martha pays a gift tax of $500 on the transfer. I. If the fair market value of the stock on June 1 of the current year is $20,000, Bob has a basis in the stock of $12,200. II. If the fair market value of the stock on June 1 of the current year is $10,000, and Bob sells the stock for $10,000 on June 2 of the current year, Bob realizes a loss on the sale of $2,000. II. A Section 179 deduction can be claimed on property held for the production of income. III. A Section 179 deduction cannot be claimed on real property. IV. A Section 179 deduction is allowed only for corporations and partnerships. a. Only I is true. b. Only I and II are true. c. Only I, II, and III are true. d. Only I and III are true. e. All of the statements are true. 45. If the total amount paid for a business is greater than the sum of the net fair market values of the assets of the business, the excess a. Only statement I is correct. b. Only statement II is correct. c. Both statements are correct. d. Neither statement is correct. 43. Bill died on April 5 of the current year. As part of his will, he leaves land that he paid $6,000 for in 1983 to his son Don. On April 5 the land is worth $11,000. However, due to local real estate conditions, the land declines in value. On July 28 it is worth only $10,000; it declines further to $9,000 on October 5 and plunges to $7,000 on December 18. I. In the absence of any special elections, Don's basis in the land is $11,000. II. If the executor elects the alternate valuation date and distributes the land to Don on July 28, Don's basis in the land will be $10,000. III. If the executor elects the alternate valuation date and distributes the land to Don on December 18, Don's basis will be $7,000. IV. In the absence of any special elections, if the executor distributes the land to Don on October 5, Don's basis in the land will be $11,000. a. Only I is correct. b. I and II are correct. c. I, II and IV are correct. d. II and IV are correct. e. All the statements are correct. 44. Which of the following statements related to the Section 179 election to expense is (are) true? I. A Section 179 deduction can be claimed on tangible personal property a. Is currently deductible. b. May be amortized over the period of 15 years. c. May be characterized as goodwill and amortized over a period of not more than 60 months. d. May be allocated to a noncompetition covenant and amortized over the period of time of the covenant. e. Is never deductible. 46. A capital asset includes which of the following? I. Cisco common stock owned by a professional chef. II. the copyright to a novel held by its author. III. real estate used in a trade or business. IV. depreciable business property. a. Only I is correct. b. I and II are correct. c. III and IV are correct. d. I, II, and III are correct. e. I, II, III, and IV are correct. 47. Douglas Cable Corporation has the following gains and losses from Section 1231 property during the current year: Casualty losses $(14,000) Casualty gains 5,000 Section 1231 gains 9,000 Section 1231 losses (6,000) No net Section 1231 losses have been deducted as ordinary losses in prior years. How will this ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 10 OF 18 information affect taxable income? Douglas's current year a. Douglas will report a net section 1231 loss of $6,000. b. Douglas will report a capital loss of $9,000 and ordinary income of $3,000. c. The transactions have no effect on Douglas's taxable income. d. Douglas will deduct a $3,000 capital loss and have ordinary income of $3,000. e. Douglas will report an ordinary loss of $9,000 and a long-term capital gain of $3,000.} 48. Stein Company purchased a drill press on November 13, 2003, at a cost of $30,000. Stein sells the drill press on January 3, 2005, for $16,000. Regular MACRS depreciation on the drill press would be $18,500, while straightline MACRS depreciation would total $12,000. I. If Stein used regular MACRS depreciation, it would have a Section 1231 gain of $4,500. II. If Stein used straight-line depreciation, it would have a Section 1231 loss of $2,000. III. If Stein used regular MACRS depreciation, it would have ordinary income of $4,500. IV. If Stein used straight-line depreciation, it would have an ordinary loss of $4,500. a. Only I is correct. b. Only II is correct. c. I and II are correct. d. I and IV are correct. e. II and III are correct. 49. Camilla paid $400,000 for a warehouse. Using 39-year straight-line depreciation, Camilla deducts $24,868 for the first two years of usage. At the beginning of the third year, Camilla sells the warehouse for $380,000. How much of the gain is recaptured as ordinary income? a. $ - 0 b. $ 4,868 c. $ 24,868 d. $380,000 e. $400,000 50. Which of the following qualifies as a likekind exchange of property? I. Commercial retail building and its land for an office building and its land. II. Yankee Food, Inc. common stock for Yankee Food, Inc. corporate bonds. III. Convenience store owner trades several cases of potato chips for a cash register. IV. A completely rented apartment building traded for a parts supply warehouse to use in business. a. Only statement I is correct b. Statements I and IV are correct. c. Statements I, II and IV are correct d. Statements I, III, and IV are correct e. Statements I and II are correct _______________________________________________________________________ END OF EXAMINATION ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 11 OF 18 BRADLEY UNIVERSITY ATG 477 FEDERAL TAXES I COLEEN S. TROUTMAN ASSOCIATE PROFESSOR, CPA, Ph.D. ANSWER KEY AND SELECTED NOTES Question 1 Answer C 2 B 3 D 4 D 5 D 6 E 7 B 8 D Comments Total tax/taxable income = average rate 16,900/80,000 = 21.1% Total tax/(taxable income + excluded income) = effective rate 16,900/(80,000+10,000) = 18.8% Average rate(平均税率)は、所得税額を「課税所得」で割って求めます。 Effective rate(実効税率)は、所得税額を「所得の合計」で割って求めます。 Tax/income = rate #1 (6%, 5%) is regressive(逆進税率) #2 (3%, 6%) is progressive(累進税率) #3(7.5%, 7.5%) is proportional(比例税率) Reasonable estimates can be used when it is impractical or impossible to get actual data. 正確なデータが取得不可能な場合、合理的な推測を用いることが認められます。 Since Debra owns > 50% of the corporation, they are related parties. Transactions between related parties are not arms-length-transactions. Losses on sales between related parties are not deductible. ※コンセプトにつきましては、補助レジュメを参照して下さい。 To be constructively received, the amount must be set aside and made available without substantial restrictions. In I insufficient funds is a restriction. In III no amount has been made available. 実際に手元に現金等を受領してなくても、なんの制限(restriction)もなく自由に使え る状態にあれば、受領したとみなされます。 Ⅰ:January 15 , Year 2 ⇒ Year 2 に認識。 Ⅱ:December 31, Year 1 ⇒Year 1 に認識(みなし受領)。 Ⅲ:Year 1 には契約しただけで、支払いは Year2 である。 Income is realized in the year of the sale but the taxpayer does not have the funds to pay the tax. Recognition is postponed until proceeds are received. ※コンセプトにつきましては、補助レジュメを参照して下さい。 Operating income + Sec. 1231 gain – nondeductible expenses – distributions. 12,000 + 4,000 – 2,000 – 5,000. S コーポレーションの株主の株式の basis について(TAC テキスト Vol.2 の内容)。 パートナーの持分の basis の計算とほとんど同じですが、S Corp の株主の株式の basis の算定においては負債の変動による調整は行われません。 DRD = 70% X lesser of TI before DRD or dividend. Sales – expenses + dividends = TI before DRD 270,000 – 275,000 + 20,000 = 15,000 DRD = 70% X 15,000 = 10,500. TI = 15,000 – 10,500 = 4,500 法人の受取配当金控除について(TAC テキスト Vol.2 の内容)。 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 12 OF 18 9 C 10 D 11 A 12 C 13 C 14 C 15 E 16 C 17 D 18 C 19 B Beg. Basis + increase in debt – distributions = basis before loss 30,000 + 40,000 -24,000 = 46,000. Share of loss equals 160,000. Loss limited to basis パートナーシップからの分配について(TAC テキスト Vol.2 の内容)。パートナーシッ プからの分配は一般的に持分割合に比例(pro rate distribution)して行われます。 Charitable contribution = 10% X TI before CC CC = 10% X (50,000 TI + 20,000 CC incorrectly deducted) = 7,000 TI = 70,000 – 7,000 = 63,000 法人の寄付金控除について(TAC テキスト Vol.2 の内容)。 Exclude 45,000/120 payments = 375/mo Taxable = 600 – 375 = 225. Four months = 225 X 4 = 900 拠出金(元本)の払戻しに相当する部分は不課税となります。 Prizes and awards are generally taxable. Exceptions: 1. tangible personal property for employee safety achievement or length of service. 2. Scientific, etc. achievement if don’t apply for the award, no services are required and give award to qualifying charitable org. or gov’t. Stmt I is not correct since received cash. Stmt III is correct because a beauty contest is not a qualifying achievement. ※Prizes and awards に関する Exception 1 は U.S.CPA 試験では出題されません。 High income taxpayers must include 85% of SS benefits in income. Rule of thumb: Income < $25,000, SS benefits are not taxable. Income > $50,000, 85% of SS benefits are taxable. 高額所得者の場合、社会保障給付額の 85%が課税対象となります。 ※このような計算問題が U.S.CPA 試験で出題される可能性は極めて低いと思います。 Net LTCL for first year = 9,000. Deduct 3,000 carryover 6,000. Second year with the carryover loss = 3,000 net gain. Year 1 Year 2 6,000 Gain 9,000 9,000 純キャピタル・ロスの金額 Net gain 3,000 通常所得と損益通算される金額 <3,000> 6,000 翌年以降に繰越される金額 Advance receipts by accrual basis taxpayers are income when received unless they relate to services. 前受収益の扱い。 The “gift” lacks donative intent. There is a business relationship and an expectation of continued business dealings. ※コンセプトにつきましては、補助レジュメを参照して下さい。 Replacement property must be the same functional use except when real property is condemned. Condemned real property can be replaced by any real property. ※上記については、U.S.CPA 試験では出題されません。 Annual salary $50,000 Contributions to qualified pension plans (2,000) 源泉※1 非課税のため差し引く。 Group-term insurance premiums are excluded for 50,000 of coverage. Excess is taxable. 50 X 1.08 = 54. 54 (会社が負担した生命保険料:$50,000 の制限あり) Health insurance premiums paid by employer are excluded (会社が負担した医療・傷害保険料) Contributions to flexible benefit plans (1,800) 源泉※非課税のため差し引く。 Gross income $46,254 ※1 日本では、社会保険料控除となります。 An insolvent taxpayer must recognize income from debt discharge to the extent of solvency after. Net assets after equals $490,000 – ($500,000 – 30,000) = 20,000 ※上記については、U.S.CPA 試験では出題されません。 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 13 OF 18 20 C Since 3 of the five days are business, the trip is primarily for business and the full airfare can be deducted. Airfare $400 Lodging (110 X 3) 330 Meals (60 X 3 X 50%) 90 Incidentals (20 X 3) 60 Total $880 ビジネス出張とプライベート旅行を合わせて行うケースがありますが、ビジネス部分 21 D 22 C 23 D 24 B 25 C 26 C 27 E 28 D 29 B のみが控除の対象となります。但し、飛行機代のみ全額控除できます。 I. $300 of the $500 is child support since it is contingent upon age of the child. II. Value of lodging is excluded when it is on the business premises and required as a condition of employment. III. SS benefits are excluded for low income taxpayers. IV. Not a scholarship when services are required so cannot exclude. ※選択肢の兼ね合いでⅠ&Ⅲが正解を選択します。 Cash dividends are taxable and stock dividends are excluded. The $99,000 must be allocated to 44,000 shares giving a basis of $2.25 per share. 株式配当で受領した株式が旧株式と同一の場合と仮定して計算します。一株あたりの 新しい basis は、旧株式の basis を総株式数で割った金額となります。 Fines and penalties are not deductible since they are contrary to public policy. 罰金などのいわゆる公共の秩序に反するものは、一切控除できません。 Political contributions are not deductible. Attempting to influence legislation (lobbying) is not deductible. Monitoring is deductible. Ⅰ:政治献金やⅢ:ロビー活動の費用は一切控除できません。但し、Ⅱ:モニターす る費用は事業経費として控除できます。 Office must be used exclusively, on a regular basis as the principal place of business. Home offices for employees must be a condition of employment. I. principal place of a business not principal business. II. Condition of employment? III. Must be a business. 事務所兼住宅について。 ※上記については、U.S.CPA 試験で出題される可能性は極めて低いと思われます。 Must improve skills in job or be required by law or employer. Cannot be a minimum requirement to enter the profession nor prepare for a new job. I. New trade. II. No job. III. Improve skills and required by law. Itemized deduction の雑控除における教育費控除について。 Entertainment must be directly related to business or associated with business. Business must be discussed during entertainment or a substantial business discussion must occur before or after the entertainment. I. No business relationship. II. Meets neither criterion. III. Meets associated with. 事業に直接的に関連した交際費のみ、事業経費として控除することができます。 ※上記の判別についても U.S.CPA 試験で出題される可能性は極めて低いと思います。 Is not a real estate professional since >50% of time is not spent in real property trade or business. Satisfies active participation test (owns at least 10% and manages) so can deduct $25,000 その納税者の人的役務の 50%超が、納税者が実質的に関与している活動である(か つ、年間 750 時間以上実質的に関与していること)場合、不動産専業者として扱われ ますが、これには該当しません。950 時間/950+1,150 時間=45%。従って、Susan 氏の賃貸活動は、Passive activity となります。 ※上記の不動産専業者については、U.S.CPA 試験で出題される可能性は極めて低いと 思われます。 Mom and Pop Exception(不動産賃貸所得に関する特例)は、個人の納税者が賃貸活動 に活動的に関与(actively participate)している(なおかつ、その活動に対する持分の 10%を所有している)場合に適用されます。Susan 氏にはこの特例が適用され、AGI が$100,000 を超えていないため、他の所得と年間$25,000 まで相殺(損益通算)が可 能です。 Prepaid interest must be capitalized and amortized for both cash and accrual basis taxpayers. 前払利息は、現金主義・発生主義に関わらず、資産計上され期間配分されます。 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 14 OF 18 30 B 31 D 32 D 33 B 34 C 35 A C 36 C 37 C 38 D 39 B 40 C The all-events test and economic performance test must be satisfied. Estimates are not allowed and economic performance does not occur until repairs are done. ※ 上記の2つのテストについては、U.S.CPA 試験に出題されません。 Write off 40% X $4,000 = 1,600 in Year 1 as ordinary loss. Write off balance (2,400 – 1,000 = 1,400) in Year 2. 問題文$0.60 on the dollar より、Write off 40%を計算します。 Investment expenses other than interest are deducted as miscellaneous itemized deductions. 投資関連費用は、Itemized deduction の雑控除にて控除することができます。 Closely held corporations can use passive losses to offset active income only. Net passive losses of individuals are not deductible. PAL ルールは Closely held corporation(閉鎖会社)にも適用されます。但し、閉鎖会 社の Passive loss は、能動的所得(active income)と損益通算することが可能です が、ポートフォリオ所得(portfolio income)と損益通算することはできません。 ※ 上記の閉鎖会社における扱いについては、U.S.CPA 試験に出題されません。 Losses on sales between related parties are not allowed. Lisa cannot recognize the $2,000 loss. Disallowed losses can be used to offset gains on subsequent sales to nonrelated parties. Burt’s $4,000 gain can be reduced to $2,000. 関係者間取引に該当します。 Losses on sales of personal use assets are not allowed. Losses on sales of personal use assets are not allowed. Increase in AGI = -7,000 + 4,000 + 8,000 = 5,000 ※正誤!正解は選択肢の c となります。 -7,000 municipal bond + 4,000 stamp collection - 8,000 ABC Common Stock = net capital loss 11,000 Decrease in AGI = $3,000 I. There must be physical damage. II. Loss equals lesser of decline in value (40,000) or adjusted basis (25,000). Deductible loss is 25,000 loss minus 20,000 insurance = 5,000. III. Loss equals lesser of decline in value (70,000) or adjusted basis (80,000). Deductible loss is 70,000 loss minus 60,000 insurance minus 100 floor = 9,900. Ⅰ:Rental house A はトルネードによる被害はありません。 Over-the-counter vitamins do not qualify. Total qualifying amounts less reimbursement $2,180 Less: 7.5% X 25,000 1,875 Deduction 305 Over the counter drugs 以外の合計$2,580-保険からの払戻し$400=$2,180 となりま す。AGI の 7.5%を超過する部分のみ、控除可能です。 Points on acquisition debt of principal residence are deductible in the year paid. 住宅取得ローンに関連して支払った融資手数料は、前払利息とみなされますが、支払 った年度に全額控除することができます。従って、選択肢の d が正解となります。 Loan $220,000 < $1,000,000 max. $7,000 interest on acquisition indebtedness $2,200 points on acquisition indebtedness $9,200 Deductible taxes are state, local, and foreign income taxes, real property taxes, and personal property taxes based on value. Federal taxes, sales tax and gift tax are not deductible. ※ 正誤!Sales tax は現行の税法においては選択控除が認められています。この問題に おいては、州所得税の大きいため、州所得税を控除します。 前年度の州所得税 $1,000+州所得税の予定納税額$2,400+財産税$2,450(自宅など) +コンドミニアム(別荘)の固定資産税$1,100=合計$6,950 AGI$35,000X50%=$17,500 Cash to church $ 200 Stock FMV 1,800 ←LTCG property の評価。 Clothing Lesser of basis or FMV 200←現物寄付の評価の原則ルール。 Total 2,200 Raffle とは慈善のための宝くじですが(対価があるため)寄付金控除の対象とはなりま せん。Chamber of Commerce とは、商工会議所の会費です。 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 15 OF 18 41 D 42 A 43 C 44 D 45 B 46 B A 47 E Scholarships are not included in the support test. A sibling can be a qualifying child. There is no maximum income level for a qualifying child. 兄弟についても、Qualifying Child の規定(所得制限なし)が適用されます⇒Ⅱは誤り となります。Support Test における生活費には、衣料費、食費、住居費、医療費、教育 費、娯楽費、交通費などが含まれることになります。生活費の 50%超の計算には、奨 学金、生命保険料などは含まれません。従って、George 負担:$3,500 / 8,500 = 41% ⇒Ⅰは誤りとなります。Head of household status は、子供でなくても親族であれば適 用可であり、Ⅲは誤りとなります。George は Ben の扶養家族 (Qualifying Child) とな るため、Ben は Head of household status を用いることが可能です⇒Ⅳのみ正しいで す。※上記の Support Test の生活費の詳細については U.S.CPA 試験で出題される可能 性は極めて低いと思います。 I. When FMV>donor’s basis, donee’s basis equals donor’s basis + the portion of the gift tax related to the appreciation. $12,000 + 500X(8/12⇒8/20) = 12,200.⇒Ⅰは正しい。 ※正誤!上記解説中の 8/12 は 8/20 の誤りです。 含み益がある資産の贈与の場合、Donee の basis は、Donor の basis を引き継ぎます。 なお、贈与税調整額$200【=含み益$8,000(FMV20,000-basis$12,000)/ 総贈与額* $20,000×贈与税額$500)が加算されます。本来であれば、総贈与額*は FMV より Annual exclusion を差し引いて求めることになりますが、この問題では考慮されていま せん。※贈与額調整額の加算は、U.S.CPA 試験では出題されません。 II. When FMV < donor’s basis, basis for the loss is FMV, so there would be no loss. 含み損がある資産の贈与の場合に、Donee が第三者に売却して Loss を計算する場合、 Donee の basis は贈与日の FMV$10,000(第三者への売却価格と同額)となるため、 $2,000 の Loss は一切認識されません。 Basis = FMV at date of death. Can elect alternate date of 6 months after death. If the election is made and property is distributed between the two dates, basis = FMV at date of distribution. Ⅰ:代替評価を選択していない場合、死亡日の時価$11,000 を用いる。従って正しい。 Ⅱ:代替評価を選択した場合、死亡日から 6 カ月以内に分配された資産については、 その分配を行った日の時価。⇒7/28 の時価$10,000。従って正しい。 Ⅲ:代替評価を選択した場合。12/18 に分配が行われているが、死亡日から 6 か月後を 過ぎているため、死亡日から 6 か月後の時価。⇒10/5 の時価 9,000。従って誤り。 Ⅳ:代替評価を選択していない場合、死亡日の時価$11,000 を用いる。従って正しい。 Qualifying property is tangible personal property used in a business. The election is available for corporations, partnerships and individuals. Sec.179 即費用化の選択は、「事業用」の有形「動産」に適用されます。 Ⅰ:正しい。 Ⅱ:事業用に限定されているため、誤り。 Ⅲ:不動産には適用されないため、正しい。 Ⅳ:Sec.179 は、自営業者、法人、パートナーシップなどに適用されるため、誤り。 A, C, D, and E are all examples of purchased intangibles that qualify for the 15-year amortization. ※上記解説は無視してください。 営業権は、税法上、15 年で償却することができます。 Property held as an investment and personal use property are capital assets. Business use assets and inventory are not. ※正誤!選択肢 a が正解となります。 Copyright held by the original artist is non-capital assets. 創作した者により所有されている著作権は、Capital asset ではありません。 Step #1: net casualty loss = 9,000 – deduct as ordinary loss Step #1: net Sec. 1231 gain = 3,000 – treat as LTCG 自宅などの個人使用の資産(personal use property)から生じた災害損失は、Itemized deduction にて Ordinary loss として控除することができます。Net Sec.1231 gain は長 期キャピタルゲインとして扱われます。 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 16 OF 18 48 E 49 A 50 B Property used in a business is Sec. 1231 property. When tangible personal property used in a business is sold at a gain, the depreciation recapture rules under Sec. 1245 apply. Ordinary income must be recognized up to the amount of depreciation taken. The balance is a Sec. 1231 gain. If the property is sold at a loss, it is a Sec. 1231 loss. MACRS Amount realized $16,000 -adjusted basis (30,000 cost – 18,500 MACRS A/D) 11,500 Gain realized 4,500 Ordinary income (up to MARCRS A/D) 4,500 1 年超保有の事業用資産は Sec.1231 property となります。この問題における Drill press(personal property:動産)の保有期間は 11/13/2003~1/3/2005 となり、これに 該当します。Sec.1231 GAIN($4,500)となる場合には、Sec.1245 リキャプチャーを 考えます。過去のすべての減価償却部分までは Ordinary income として扱い、残りを Sec.1231 gain として扱うことになります。 Ⅰ:Sec.1245 リキャプチャーを考慮しなければならないので、誤り。 Ⅲ:上記の計算より、正しい。 SL 動産については、MARCS に代えて定額法に減価償却を選択することもできます。 Amount realized $16,000 -adjusted basis (30,000 cost – 12,000 ST A/D) 18,000 Loss realized 2,000 Sec.1231 loss 2,000 Ⅱ:Sec.1231 LOSS($2,000)の場合は(Sec.1245 は適用されないため)正しい。 Ⅳ:誤り。 Sec. 1250 ordinary income equals the excess depreciation taken over SL. There is no excess. Sec.1250リキャプチャーは不動産に適用され、定額法で計算した減価償却額を超過す る部分を Ordinary income として扱うという規定です。MACRS が適用される不動産に ついては、そもそも MACRS において定額法が用いられているため、Sec. 1250 リキャ プチャーの対象とはなりません。従って選択肢の a が正解です。 Amount realized $380,000 -adjusted basis (400,000 cost – 24,868 A/D) 375,132 Gain realized 4,868 Sec.1231 gain 4,868 Ⅰ:Real for real and both used in a business or held as an investment. 「事業用」または「投資用」不動産同士の交換は同種資産の交換として認められます。 従って正しい。 Ⅱ:Securities are not qualifying property. 株式・債券は、同種資産の交換の対象資産から除かれています。従って誤り。 Ⅲ:Inventory for personal property. Inventory does not qualify. 棚卸資産も、同種資産の交換の対象資産から除かれています。従って誤り。 Ⅳ:Same as I. 「事業用」または「投資用」不動産同士の交換は同種資産の交換として認められます。 従って正しい。 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 17 OF 18 Murphy & Higgins, Concepts in Federal Taxation 2008 editions, Thomson TOPICS: CHAPTER 1 CHAPTER 2 CHAPTER 3 CHAPTER 4 CHAPTER 5 CHAPTER 6 CHAPTER 7 CHAPTER 8 CHAPTER 9 CHAPTER 10 CHAPTER 11 CHAPTER 12 CHAPTER 14 Federal Income Taxation—An Overview 1,2,3 Income Tax Concepts 4,5,6 Income Sources 11,12,13,14,15 Income Exclusions 16,18,19,21,22 Introduction to Business Expenses 23,24,29,30,31 Business Expenses 20,25,26,27,32 Losses—Deductions and Limitations 28,33,34,35,36 Taxation of Individuals 37,38,39,40,41 Acquisitions of Property 42,43,44, Cost Recovery on Property: Depreciation, Depletion, and Amortization 45,46, Property Dispositions 47,48,49 Nonrecognition Transactions 17,50 Choice of Business Entity—Operations and Distributions 7,8,9,10 ATG 477 FEDERAL TAXES I JUNE 2008 FINAL EXAMINATION PAGE 18 OF 18
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