Dot Image Accounting 237 Individual Income
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The attached research case should be prepared by using RIA checkpoint online tax research database. Be sure you provide enough citations (the applicable Law) to support your analysis and conclusion.
Assume you have a tax practice. You are advise your client as his best courses of action or approach. Remember that you are representing your client as his advocate. Prepare a tax file memorandum with the facts, tax issues, law citations, analysis, and your conclusions. (See Page A- of the PH Tax Research Working Paper File handout attached.)
The memoramdum is to be no more than one page in length.
Hades died on April 13, 2006. The executor of his estate made the 2032 (a) election to use the alternate valuation date in filing Hades’ estate tax return. With the primary valuation date and amount, the estate assets would have been valued at $3.5 million. With this election, the estate assets were valued at $ 3.0 million.
A major asset of the estate was shares of SOB Corporation. Those shares were traded on an established securities market. Because the estate owned 2% of SOB’s stock, the executor secured the services of a major brokerage firm to calculate the blockage discount on the stock. Shortly, before the estate tax return due date of January 13, 2007, the executor filed Form 4768 (Extension Request for Estate Tax Return) requesting an execution for filing until July 13, 2007, and paid $400,000 in estimated taxes with the request. In early June, the brokerage firm notified the executor that it would not be able to finish the valuation on time. Another firm was engaged, and it completed the valuation on November 29, 2007. Hades’ executor finally filed the estate return on January 19, 2008 and made the 2032 (a) election.
IRS determined that a 2032 (a) election cannot be made unless the estate tax return was filed on a timely basis. A deficiency was assessed based on the asset valuation of $3.5 million rather than $3.0 million.
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Hades has secured your power of attoney to represent him with IRS.
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