2020/06/18 / Chapter 8

Exercises (Any 6):

19.
Use the BNA TAX MANAGEMENT PORTFOLIOS to answer the following questions:
a. What is the portfolio number (and section) that discusses the issue of a stuffing allocation to a
redeeming hedge-fund partner?
b. Which portfolio contains a worksheet demonstrating the attribution rules between family
members for IRC § 267? What is the worksheet number?

a.” Other Pass-thru Entities”, Portfolio 736-1st in Section V(D) in Worksheet 7

b. Portfolio 554-4th, Worksheet 10

21.
Use Westlaw Campus Research to answer the following questions:
a. What is the Westlaw Key Number for Gross Income under Taxation?
b. Find Stewart v. U.S., 106 F.2d 405. Which court presided over this case?
c. According to Westlaw’s KeyCite flag, what is the status of this case?
d. Which court reversed the decision cited in b?

a. Westlaw key number is 3447

b. Ninth Circuit Court of Appeals presided
c. The flag is red signaling severe negative status
d. The US Supreme Court reversed the case

22.
Use Westlaw Campus Research to answer the following questions:
a. What is the New Mexico regulation that defines “base income?”
b. Find the Armstrong v. Commonwealth of the Northern Mariana Islands Supreme Court action
that occurred in June 2010. Was certiorari granted?
c. How many law reviews are available as secondary tax sources?
d. Who wrote the article “Tax Compliance as a Wicked System” in the Florida Tax Review?

a. N.M.S.A. §7-2-2
b. The Supreme Court denied certiorari.
c. 5 diverse tax law reviews are available
d. Written by Morgan Holcomb

23.
Use Westlaw Campus Research to answer the following questions:
a. Locate the 2008 Supreme Court case, Boulware. Provide the Federal, Westlaw, RIA, and CCH
citations for the case.
b. Under Practice Areas, what secondary resources are available for Securities?
c. Select one of the resources located in b and determine its contents.
d. Find IRC § 67. Using the context and analysis tab, what is the reference to the Encyclopedia
that covers the deduction of impairment-related work expenses? Based on this analysis, are these
expenses subject to the 2 percent floor?

a. Citations: 128 S Ct 1168, 552 US 421, 101 AFTR 2d 2008-1065, 2008-1 USTC ¶50.206
b. Secondary resources available: American Law Reports – Securities and Securities Law
Reviews & Journals.
c. The contents for the items in part b include: Securities Law Reviews & Journals – Fordham
Journal of Corporate & Financial Law and the Journal of Business & Securities Law American
Law Reports.
d. Reference: 34 Am. Jur. 2d Federal Taxation ¶16526.
Impairment-related work expenses aren’t subject to the 2% floor.

24.
Use Westlaw Campus Research to answer the following questions:
a. Find the House proceeding during which the bill to add flu vaccines to the list of taxable
vaccines was discussed on the House floor and was passed by the House. What is the date of
this proceeding and who introduced the discussion?
b. Indicate your search strategy for a. Include your search terms, databases chosen, and search
iterations.
c. Which statutes were affected by the new public law related to including flu vaccines on the
taxable list?
d. Which key number is suggested for this code section?

a. The citation for this discussion is 159 Cong. Rec. H3704-01, 2013 (WL 3013727). The
motion was introduced by Representative Gerlach on February 4, 2013. The bill was signed
into a law by the President on June 25 th, 2013.
b. Select Proposed and Enacted Legislation and keyword search influenza vaccine tax. The
results include the Public Law passing the measure and the Legislative History materials tab
that provides the congressional records for the bill.
c. IRC §4132
d. Key Number 220k4325.

25.
Use Westlaw Campus Research to answer the following questions:
a. What is subchapter B of title 26, subtitle A, chapter 1 of the Code of Federal Regulations?
b. What IRC section covers the inclusion of the rental value of parsonages?
c. What is the key number for medical deductions?
d. In the Jack L. Hargrove case, why was certiorari granted by the Supreme Court in 2010?

a. Computation of Taxable Income

b. §107
c. Key Number 220k3366 for Internal Revenue: Expenses – Medical Expenses
d. The decision was cleared out and remanded to the 7th Court of Appeals for additional
considerations.