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$20,000 received annually at the end of $100,000 (1 − t) = $60,000 The six steps of the tax research process

years 1 through 5 followed by $13,000 1. Get the facts


received annually at the end of years 6 (after-tax income of Transaction 1 = 2. Identify the issues
through 10. The discount rate is 15 after-tax income of Transaction 2) 3. Locate authority
percent. 4. Analyze authority
t = 40% marginal tax rate 5. Repeat steps 1-4
($20,000 × 3.352 discount factor) + 6. Communicate conclusions
0.497 discount factor ($13,000 × 3.352 Mr. Fuentes’s after-tax yield on the
discount factor) = $88,697 corporate bonds is 3.23 percent (4.75% Milt realized a $15,000 long-term capital
before-tax yield − [4.75% × 32% gain (collectibles gain) taxed at a
marginal tax rate]). maximum rate of 28 percent.
Total income $ 95,600 AGI $ 462,700 Ms. Lincoln’s medical expense
Above-the-line deduction for one-half AGI threshold (400,000) deduction is $9,510 ($14,340 − $4,830
SE tax (2,953) Excess AGI $ 62,700 [$64,400 AGI × 7.5%]), and her tax
AGI $ 92,647 $62,700 excess AGI ÷ $1,000 (rounded savings from the deduction is $2,092
Standard deduction (27,700) up) 63 ($9,510 × 22%). The after-tax cost of the
QBI deduction (20% × ($41,800 − Maximum total credit $ 6,000 expenses is $12,248 ($14,340 − $2,092).
$2,953)) (7,769) Phaseout ($50 × 63) (3,150)
Taxable income $ 57,178 Child credit $ 2,850 The present value decreases as the
Income tax on $57,178 (married filing discount rate increases.
jointly) $ 6,421 $6,500 child credit [$2,000 × 3 children
under age 17 plus one non-child A taxpayer is neutral concerning paying
The tax character of income is dependent ($500)]. an identical amount of implicit or
determined strictly by tax law. explicit tax.
The Kilos’ realized gain on sale was Entity variable one controlled subsidiary $52,000 total income − $1,800 =
$715,000 ($1,150,000 amount realized − to another controlled subsidiary. $50,200 AGI − $27,700 standard
$435,000 cost basis), and their taxable deduction = $22,500 taxable income.
long-term capital gain was $215,000 The child tax credit for non-child
($715,000 − $500,000 exclusion). Their dependents is limited to $500. Because only 50 percent of the meal
tax is $51,170 ($215,000 × 23.8% expense is deductible, the after-tax cost
combined 20% income tax and 3.8% is $6,981 ($7,800 − [$3,900 × 21%]).
Medicare contribution tax).
$888 taxable income. Although Besito Even as a cash-based taxpayer, Firm F In the one-year deferral method
earned only $180 of the prepaid rent can deduct only $4,720 of the interest authorized by the IRS, only the portion
this year, (15 days in December × $12), payment (the interest relating to the of the prepayment allocable to services
the income is recognized in the year four months from September 1 through performed in the year of receipt is
payment is received. December 31). included in taxable income for such
year. The remaining prepayment is
TRW’s NOL deduction is limited to 80% BDF’s 2023 payroll tax is $12,832 included in taxable income for the
of taxable income in years 2023 through ([$160,200 × 6.2%] + [$200,000 × following year.
2026. The remaining NOL is deducted in 1.45%]).
2027.
21% × $31,000 excess of book income ZEJ’s bad debt expense for financial Qualified business income of $280,000 ×
over taxable income = $6,510 deferred statement purposes is $770,000, the 20% = $56,000 tentative deduction.
tax liability. year-end addition to the allowance for Deduction cannot exceed the greater of
No deferred tax asset or liability from bad debts.
permanent book/tax difference. ZEJ’s tax deduction for bad debts is $50,000 (50% × $100,000 wages) or
21% × $55,000 excess of taxable income $840,000, the amount of actual write- $26,250 (25% × $100,000 wages + 2.5%
over book income = $11,550 deferred offs of accounts receivable. × $50,000 unadjusted basis of tangible
tax asset. depreciable property).
Section 179 does not apply because the Since the tentative deduction is more
Self-employment tax = $16,955 = total acquisition cost exceeds than $50,000 (greater of 1) or 2) above),
$120,000 × 92.35% × 15.30%. $4,050,000. Ms. Alvarez’s QBI deduction is $50,000,
before the overall taxable income
limitation.
Total cost of depreciable personalty If the equipment is purchased in 2022, Mr. Zan can deduct $1,880 of the
$ 1,580,000 100% of the cost is immediately expenditures ($5,000 − $3,120 excess
Section 179 election/2023 dollar deductible through bonus depreciation expenditures over $50,000) and must
amount(1,160,000) (or a combination of Section 179 and capitalize the $51,240 remainder. He
Tax basis after 179 deduction $ bonus depreciation). can elect to amortize the capitalized
420,000 cost over 180 months at the rate of
80% bonus depreciation(336,000) Firm L cannot deduct any of the Section $284.67 per month. First-year
Tax basis after bonus depreciation 179 expense because it has no taxable amortization would be $854 (3 months
$ 84,000 income. The entire $21,300 × $284.67), and Mr. Zan’s first-year
Year 1 percentage for 7-year MACRS nondeductible expense is carried over deduction would be $2,734 ($1,880 +
0.1429 into 2024. $854).
Year 1 regular MACRS depreciation
$ 12,004 $135,000 ÷ 180 months = $750 per If Lynn is a noncorporate business, the
Total deduction ($1,160,000 + $336,000 month amortization. Underhill’s first- 20 percent recapture rule is
+ $12,004) $ 1,508,004 year deduction is $1,500 (2 months × inapplicable. Because Lynn claimed only
________________________________ $750). straight-line depreciation on the
$24,500 × 92.35% × 15.3%. warehouse, the entire $82,300 gain is
Section 1231 gain.
Underhill’s book amortization for Roof Corporation has $15,500 He must recognize the interest as
purchased goodwill is zero. nonrecaptured Section 1231 losses from income in 2023 under the doctrine of
Consequently, the $1,500 tax deduction year 1 and year 3 ($1,500 remaining constructive receipt.
is a favorable difference between book from year 1, after recapture against year
and taxable income. At a 21% tax rate, 2 gain and $14,000 from year 3). ($9,882,590 + $447,600 permanent
the difference results in a $315 deferred Therefore, the entire $7,500 Section differences) × 21% = tax expense per
tax liability. 1231 gain recognized in year 4 is books
recaptured as ordinary income.
Lynn must recognize $16,460 gain (20% Because Mr. Zhao does not own at least
× $82,300 recognized gain) as ordinary In year 5, Roof has $8,000 80 percent of ZJL’s outstanding stock
income under the 20 percent recapture nonrecaptured Section 1231 loss immediately after the exchange, he
rule. The $65,840 remaining gain is remaining from year 3, after recapture must recognize the entire $154,000
Section 1231 gain. of the year 4 gain. Therefore, $8,000 of realized gain ($400,000 FMV of stock
the year 5 gain is ordinary and the received − $246,000 adjusted basis of
$1,000 remaining gain is treated as a business assets transferred) on the
capital gain. exchange of property for stock.
Hardy realizes a $30,000 gain ($90,000 Qualifying property takes a substituted FF realized a $35,300 gain ($250,000
amount realized [$77,500 FMV of basis. insurance reimbursement − $214,700
property acquired + $12,500 boot adjusted basis) on the involuntary
received] − $60,000 tax basis of Employees don't include the value of conversion of its warehouse. Because FF
transferred property). Hardy recognizes any compensatory fringe benefits in spent at least $250,000 on the
$12,500 gain equal to the boot received. gross income because the benefit construction of a replacement building
Its basis in the property acquired is doesn't consist of a direct cash and the replacement occurred within
$60,000 (substituted basis of property payment. the two taxable years following the year
transferred). of the conversion, it does not recognize
The $4,733,000 taxable gift ($4,750,000 any of the realized gain. FF’s basis in the
Foreign tax credit limitation: $449,400 × − $17,000 annual exclusion) is less than replacement building is $264,700
($240,000 foreign source income ÷ Mr. Ito’s $12.92 million lifetime ($300,000 cost − $35,300 unrecognized
$2,140,000 taxable income) = $50,400 exclusion, so no amount of the gift is gain).
subject to gift tax.
Which of these corporations form an Dividend deduction for recipient corp State M apportionment percentage:
affiliated group eligible to file a 115.94% ÷ 3 = 38.65% would be 0.3865.
consolidated tax return? Groups that Less than 20% = 50%
own 80% or more of the other group. 20% - 79% = 65% State N apportionment percentage:
80% or more = 100% 184.06% ÷ 3 = 61.35% would be 0.6135.
Mr. Forest, a single taxpayer, recognized of Section 1244 stock. What is the $50,000 ordinary and $202,000 capital
a $252,000 loss on the sale character of this loss?

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