Complete the following 3 separate and unrelated research problems using the Checkpoint software included with your textbook. Be sure to cite all sources that support your overall conclusions with...


Complete the following 3 separate and unrelated research problems using the Checkpoint software included with your textbook. Be sure to cite all sources that support your overall conclusions with citations formatted according to CSU-Global Guidelines. Provide your answers in a Microsoft Word document and clearly label each part. Submit your portfolio project through the assignment link by Sunday midnight of Week 8.
Problem 1
Patrick Zimbric:k and his son, Dan, own all of the outstanding stock of Osprey Corporation. Both Dan and Patrick are officers in the corporation and, together with their uncle, John, comprise the entire board of directors. Osprey uses the cash method of accounting and has a calendar year-end. In late 2006, the board of directors adopted the following legally enforceable resolution (agreed to in writing by each of the officers):
Salary payments made to an officer of the corporation that shall be disallowed in whole or in part as a deductible expense for Federal income tax purposes shall be reimbursed by such officer to the corporation to the full extent of the disallowance. It shall be the duty of the board of directors to enforce payment in each such amount.
In 2007, Osprey paid Patrick $560,000 in compensation. Dan received $400,000. On an audit in late 2010, the IRS found the compensation of both officers to be excessive. It disallowed deductions for $200,000 of the payment to Patrick and $150,000 of the payment to Dan. The IRS recharacterized the disallowed payments as constructive dividends. Complying with the resolution by the board of directors, both Patrick and Dan repaid the disallowed compensation to Osprey Corporation in early 2011
Dan and Patrick have asked you, their accountant, to determine how their repayments should be treated for tax purposes. Dan is still working as a highly compensated executive for Osprey while Patrick is retired and living off his savings.
Prepare 3-4 double-spaced pages describing the results of your research and making recommendations to your client.
Use the online access code for the Checkpoint Student Edition to locate, cite, and discuss at least one source (e.g., tax law, case, and/or ruling) to support your conclusion.
(Partial list of research aids: Section 1341. Vincent E. Oswald. 49 T.C. 645 (1968)).
Problem 2
The accrual basis Four Winds Partnership owned and operated three storage facilities in Milwaukee, Wisconsin. The partnership did not have a section 754 election in effect when partner Suzanne sold her 25% interest to Paul for $250,000. The partnership has no debt. There are no section 197 assets, and no depreciation recapture potential exists on the storage facility buildings.

May 12, 2022
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