R.A6

| July 5, 2016

Paper , Order, or Assignment Requirements

RESEARCH ASSIGNMENT 6 Combined Sources (1) Find and properly cite a case in which the taxpayer and the IRS disagreed as to whether the taxpayer was bound by the terms of a closing agreement entered into in connection with a prior audit. (2) Find and properly cite a case decided after the year 2000 in which a Big 4 accounting firm litigated the issue of whether either (i) its workpapers or (ii) its communications with a client were protected from discovery by the IRS (i.e., the IRS had issued a summons to the accounting firm). Also briefly describe exactly what material(s) the IRS was seeking. (3) Find and properly cite a case in which a taxpayer sought by judicial action to force the IRS to release certain information pursuant to a FOIA (Freedom of Information Act) request, information that the IRS had declined to release. Briefly state the outcome of the case. (4) Find and properly cite a case involving a “Kovel agreement” or otherwise relying on the well-known 1961 Kovel case. Briefly describe the Kovel doctrine. (5) Find and properly cite a case involving income and/or deductions arising in the legal (under state law) marijuana business. (6) Find and properly cite a case in which the IRS was attempting to assert the section 6672 penalty against an individual (a “responsible person”) for a company’s failure to collect withholding taxes (payroll taxes) or to pay withheld taxes to the IRS. State the outcome of the case. 2 (7) Exactly why did Hollywood actor Wesley Snipes go to prison? Cite a case that explains the precise reason and briefly explain. (8) Same question again but with respect to a certain insider at Dynegy Corporation. (9) Find and properly cite a 21st century case involving inventory accounting (i.e., tax accounting) in which the court cites and relies on the Supreme Court’s 1979 decision in Thor Power Tool Co. v. Commissioner. (10) Find and cite a case in which a taxpayer argued that the IRS should have accepted her or his “offer in compromise” with respect to a pending tax assessment

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