Embery MBAA667 all weeks discussions and assignments

Embery MBAA667 all weeks discussions and assignments 

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Embery MBAA667 all weeks discussions and assignments 

Embery MBAA667 Module 14 Discussion latest 

14 Discussion: Tax Research 

21 21 unread replies 85 85 replies 

Discussion Keyboard Key 

Class discussions are an integral part of your learning in this course and the selected topics or questions will help 

sharpen your critical thinking and written communication skills as you study Federal Taxation The graded discussions 

focus on tax research 

Twenty (20) percent of your course grade will come from your responses to these discussions based on your tax 

research submitted on time and as directed in the appropriate discussion forum A portion of the grade will come from 

responses to your peers 

Tax Research 

Go to the US Tax Court website wwwustaxcourtgov (Links to an external site) and spend some time exploring the 

website 

What type of information can be found on the site? 

Find a recent summary opinion or a memorandum decision 

Briefly, describe the principal issue in the case and explain the Tax Court’s decision 

Discuss the most significant points of the case 

Attach the PDF file of the summary opinion or the memorandum decision 

It is highly recommended that you submit your initial post by midweek Posting in a timely manner offers your 

classmates sufficient opportunity to respond to you in this discussion 

For full credit, respond to at least two of your classmates in the forum by the posted due date Review the grading 

rubric for detailed grading requirements 

Note: Discussion rubrics may be accessed by selecting the gear icon gearjpg above and choosing “show rubric” from 

the drop-down menu 


23 Discussion: Gross Income 

4343 unread replies6464 replies 

Various Federal stimulus provisions were designed to assist state and local governments in borrowing funds, 

leveraging the gross income exclusion for such bond interest so that such jurisdictions would have increased access

to funds One of the justifications for these provisions was that state and local governments cannot run budget deficits 

and cannot “print money,” so the recent recession put them in a difficult cash-flow position 

Audits of the use of these borrowed funds showed that some of the bond proceeds were used by the jurisdictions to 

participate in “public-private partnerships,” where government funds were used to assist private entities in expanding 

in or relocating to the jurisdiction Specifically, bond proceeds were found to have been used to provide targeted roadbuilding 

and utility construction projects to benefit large commercial entities 

1 Is this an appropriate use of the gross income exclusion for state and local bond interest? Why or Why not? 

2 Read the posts of your classmates and reply to at least two of your peers 

3 Review the rubric which will be used to evaluate each discussion board posting for this course 






33 Discussion: Deductions and Losses 


Earlier this year, Troy and Ann Hatten, two successful airline pilots made a cash investment for a limited partnership 

interest in a Florida orange grove farm In addition to the cash obtained from investors, the grove’s management 

borrowed a significant amount of money to purchase the assets required to operate the farm The Hatten’s investment 

adviser pointed out that their tax loss for the first year would be more than their initial cash investment The next 

several years would bring more losses The Hatten’s feel confident about their investment in the orange grove 

1 Identify and discuss in detail the tax issues facing the Hattens 





For full credit, respond to at least two of your classmates in the forum by the posted due date 


43 Discussion: Property Transactions 


John started collecting model airplanes when he was just a young boy His collection consists of over 500 model 

airplanes, most of which were received as birthday gifts He is retiring this year and needs to downsize, therefore, he 

has decided to sell his collection He lists the model airplanes on an Internet auction site and receives an offer of 

$50,000 for the model airplane collection John sells the entire collection, except for the 3 newest airplanes purchased 

in the last year The remaining airplanes had all been owned by John for over a year 

1 Discuss the tax factors John needs to consider in deciding how to report the sale 







Embery MBAA667 Module 53 Discussion latest

53 Discussion: Individual Taxation 


Mark and Amy Hatten, live in Pensacola, FL and have recently been experiencing problems with their marriage They 

have a 4-year-old daughter, Victoria who stays with Mark’s parents during the day, while both parents work Amy 

worked to support Mark while he attended flight school, and now she has been accepted to flight school in 

Melbourne, FL Amy has decided to divorce Mark She will move to Melbourne, FL and attend flight school Victoria will 

stay in Pensacola, FL because she is very attached to her grandparents and needs the excellent child care they 

provide Amy knows that Mark will expect her to contribute costs associated with raising Victoria Amy also feels she 

needs to receive cash for her share of the property accumulated during the marriage, in order to finance flight school 

She also feels she should receive some reimbursement for her support of Mark while he was in flight school Divorce 

proceedings are expected to take several months 

1 Identify the relevant tax issues for Amy 








63 Discussion: Corporate Taxation 


Vivian and her daughter Ivy have been working together in a spa called “Viva Bien” Vivian formed the business in 

2001 as a sole proprietorship The business has become very successful over the years and Vivian’s tax accountant 

is recommending that she incorporate the business Business assets have a fair market value of $550,000 and a 

basis of $280,000 Vivian would like to give shares of stock to Ivy, because of her participation in the business 

1 What are the relevant tax issues? 








73 Discussion: Corporate Distributions and S Corporations 


Shannon Lundy is a 50% shareholder in Wing & Ground, Inc, an S corporation This year her share of Wing & 

Ground’s operating loss is $195,000 Shannon has income from several other sources 

1 Identify and discuss the tax issues related to the effects of the S corporation loss on Shannon’s tax report? 




classmates sufficient opportunity to respond to you in this discussion




 

 

 

83 Discussion: Partnership Taxation 

3838 unread replies6060 repliesThe Vivori, LLC distributes the following assets to its member, Victoria: 

$20,000 cash 

Inventory valued at $20,000 and a $10,000 basis to the entity 

Land with a $30,000 value and a $35,000 basis to the entity 

1 What issues must be considered in determining the Federal income tax treatment of the distribution? 

2 Read the posts of your classmates on their chosen summary opinion or memorandum decision and reply to at least 

two of your peers 







92 Discussion: Court Decisions 


1 In considering the validity of a prior court decision, assess the significance of the following independent scenarios 

and post your conclusions: 

a A decision was rendered by the US District Court of Wyoming, the state in which the taxpayer lives 

b A decision was rendered by the Court of Federal Claims The taxpayer lives in Wyoming 

c A decision was rendered by the Second Circuit Court of Appeals The taxpayer lives in California 

d A decision was rendered by the Supreme Court 

e A decision was rendered by the Tax Court The IRS has acquiesced in the results 

f A decision was rendered by the Tax Court The IRS has non-acquiesced in the result 







 

 

 

 

Research Problems 

Research problems are designed to help you develop better professional research, writing, and critical thinking skills 

Action 

Using the Web or an online tax library, find one instance of each of the following: 

Letter Ruling 

Action on Decision 

IRS Notice 

Revenue Ruling

Revenue Procedure 

Code Section 

Tax Regulation 

Tax treaty 

Tax Court Summary Opinion 

Tax Court Regular Decision 

Give the full citation and a brief summary of the item 

Format 

Your document must be formatted in current APA style It will be checked throughTurnitin a service that checks your 

work for improper citation or potential plagiarism by comparing it against a database of web pages, student papers, 

and articles from academic books and publications 

Submission 

Before submitting, save your document using a naming convention that includes your first and last name and the 

activity number (or description) Do not add punctuation or special characters 

Several years ago, Vivian Wright exercised all of her stock options from a startup company she helped to establish 

The stock options netted Vivian $100 million dollars Since that time she has used an investment philosophy of 

steady, careful investment in a diversified portfolio She generally buys and holds most of her stock for over one year 

Each year she engages in multiple sales and purchases She buys securities both for their growth potential and 

dividend payments Since her investment activities have been taking up so much of her time, this year, she rented a 

suite of offices, hired three investment advisers, and 2 secretaries to help She also purchased several assets for the 

office, such as a new computer and office furniture 

Vivian is now seeking some tax help Using the following partial list of research sources explain to Vivian if her 

activities are considered a business or an investment activity Please also, explain if the activities are deductions for or 

from AGI 

Higgins v CIR, 25 AFTR 1160, 41-1 USTC § 9233 (USSC, 1941) 

 

Estate of Louis Yaeger, Deceased, Judith Winters, Ralph Meisels, Abraham J Weber and the Bank of New 

York, 889 F2d 29, 89-2 USTC 9633(CA-2) 

Fredrick Mayer and Jan Perry Mayer, 67 TCM 2949 (1994) 

Rudolph W and Abbie A Steffler, 69 TCM 2940 (1995) 

Sec, 179 

Make sure to explain the logic behind your decision 

Format 

Your document must be formatted in current APA style It will be checked throughTurnitin, a service that checks your 



Submission 


activity number (or description) Do not add punctuation or special characters 

Shawn Bernoulli formed Bernoulli Air Corporation on January 3 and immediately made the S election effective for 

year one Shawn contributed $50,000 in cash in exchange for 100% of Bernoulli Air’s stock The corporation also 

obtained a bank loan for $75,000 to help finance operations As is common with new businesses, Bernoulli Air had an 

ordinary loss of $60,000 in year 1 and $12,000 ordinary loss for year 2 Additionally in year two, Shawn and his wife 

Jana divorced and as part of the divorce settlement on March 31 of Year 2, Shawn gave Jana 50% of the Bernoulli 

Air stock In the third year, business operations did much better The corporation had earnings of $40,000 ordinary 

income

Using the following partial list of research sources, help Shawn determine the tax consequences of these events, in 

particular, the usage of the S corporation losses 

IRC Sec 1366 

Reg Sec 11366-2 

Format 

Your document must be formatted in current APA style It will be checked through Turnitin, a service that checks your 



Submission 


activity number (or description) Do not add punctuation or special characters

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