ACC 547 Week 3 DQ I6-23 Problems: I8-40, C3-38, C3-58, C3-59 ,I10-52 Tax Strategy I13-65
Complete the following in Federal Taxation Comprehensive:
o Discussion Question I6-23
o Problems I8-40, C3-38, C3-58, & C3-59
o Case Study I10-52
o Tax Strategy Problem I13-65
Discussion Question I6-23
Under the related party rules of Sec. 267, why has Congress imposed the concept of constructive ownership?
Amount and Character of Loss Transactions. On September 30 of the current year Silver Fox Corporation files for bankruptcy. At the time, it estimates that the total FMV of its assets is $725,000, whereas the total amount of its outstanding debt amounts to $950,000. Silver Fox Corporation has been engaged in the resale of tax preparation and tax research-related books and software for several years.
a. At the time of the bankruptcy, Silver Fox is owned by Randall, who purchased the stock from an investor for $250,000 several years ago. Randall is single. What are the amount and character of the loss sustained by Randall upon Silver Fox’s bankruptcy?
b. How would your answer to part a change if Randall originally organized Silver Fox Corporation, capitalizing it with $250,000 of cash and assuming Silver Fox qualifies as a small business corporation?
c. How would your answer to Part a change if Randall were a corporation instead of an individual?
d. How would your answer to Part b change if Randall were a corporation instead of an individual?
Charitable Contribution Deduction Limitation. Zeta Corporation reports the following results for 2006 and 2007:
Adjusted taxable income $180,000 $125,000
Charitable contributions (cash) 20,000 12,000
The adjusted taxable income is before Zeta claims any charitable contributions deduction, NOL or capital loss carryback, dividends-received deduction, or U.S. production activities deduction.
a. How much is Zeta’s charitable contributions deduction in 2006? In 2007?