Write a tax research memo identifying the relevant facts

Assignment Help Taxation
Reference no: EM13503516

Write a tax research memo identifying the Relevant Facts, Issues Identified, Conclusions, and Authorities and Reasoning for the tax problem listed below. The underlined headings in the prior sentence are defined on page 149 of the text. Apply at least one relevant court case.

Write clearly and concisely so that the tax memo is no more than three pages. Use the APA style on margins, fonts, grammar, punctuation, writing skills, and spacing. Do not copy and paste the facts as listed below. You should include only the relevant facts and use your own words whenever possible.

Tax Problem:

Your client, a U.S citizen named Werner who only speaks German and lives in Texas, presented you with the following facts.
Werner visited his brother Klaus in Washington, DC. At the time, Werner was under contract to a German soccer team and was expected to return to the team to begin play for the fall 2013 season. Werner's brother Klaus was in love with American football and was a huge Washington Redskins fan. The Redskins had recently lost their regular kicker to an injury. They picked up a new kicker on waivers, but he was a disappointment. Knowing of Werner's kicking ability; Klaus was convinced that Werner could help the Redskins. Klaus, an amateur American football player himself, trained Werner in kicking field goals. Klaus took Werner to a Redskins workout and introduced him to the kicking coach. As a result, Werner was given a tryout by the Redskins, who were desperate for a good kicker. Werner's performance was far superior to others at the tryout, and the Redskins offered him the job. Werner was reluctant to accept the offer because he had planned to return to Germany in a few weeks to continue his soccer career. Considerable encouragement from Klaus and the Redskins organization seemed to be in vain until the Redskins, at Klaus's suggestion, offered Werner a $100,000 bonus. At this point, Werner overcame his reluctance and signed a contract, which Klaus co-signed as a witness and interpreter. Economically speaking, the regular salary offered by the Redskins was considerably more attractive than his salary as a soccer player in Germany. Grateful to his brother for assisting as an interpreter and negotiator, and for encouraging him to stay, Werner instructed the Redskins to pay $15,000 of the negotiated bonus directly to Klaus. Klaus reported the $15,000 as other income on his 2013 income tax return and paid the appropriate tax. After examining Werner's 2013 tax return, the IRS made a deficiency assessment claiming that the $15,000 paid to Klaus constituted income to Werner and should thus be included in his income.
Your manager has asked you to prepare a tax research memo indicating how the $15,000 should be treated for tax purposes for Werner.

Reference no: EM13503516

Questions Cloud

The audit staff at haskell & white and the partners seek : Assume that you have joined the audit staff at Haskell & White and the partners seek
Manual general ledger project : Manual General Ledger Project
How to accrue and measure such interest payment : James Olds buys a four-year, $1,000,000 certificate of deposit from the Second National Bank. James will receive 5% interest in year 1; 5.5% in year 2; 6% in year three; and 6.5% interest in year 4. If James "redeems" this certificate before ..
Write a tax research memo identifying the relevant facts : Write a tax research memo identifying the Relevant Facts, Issues Identified, Conclusions, and Authorities and Reasoning for the tax problem listed below. The underlined headings in the prior sentence are defined on page 149 of the text. Apply ..
Thomas employment-related expenses : Thomas's employment-related expenses
Make an income statement for the company : Prepare a schedule of cost of goods sold - prepare an income statement for the company and prepare an income statement for the company
Ethical issues and social accountability in accounting : A title / cover page, which indicates basic information such as Subject title, Subject code, Trimester number, Assignment title, group members' full names and KOI student numbers, word count and name of the tutor.
Explain the velocity of a hydrogen molecule after absorbing : what is the velocity of a hydrogen molecule after absorbing a photon @ 58.4 nm? what is the translational energy of the molecule in J mol-1

Reviews

Write a Review

 

Taxation Questions & Answers

  Prepare a memorandum that outlines the tax consequences

Prepare a memorandum that outlines the tax consequences of each of the three alternative acquisitions

  Aviss taxable income for the year is 300000 and bests

aviss taxable income for the year is 300000 and bests taxable income for the year is 425000. for each of the scenarios

  Advise the director of ruby pty ltd of the tax deductibility

Advise the directors of Ruby Pty Ltd of the tax deductibility of the above amounts. You must make reference to appropriate authorities and legislation.

  Cathy the manager of cathys catering inc uses

cathy the manager of cathys catering inc. uses activity-based costing to evaluate the costs of her catered parties.

  Discuss the income tax implications

Discuss the income tax implications of the following, stating which sections of the ITAA 1997 or ITAA 1936, if any, are most relevant.

  Fringe benefits tax liability for the year ended

Advise Chatswood Pty Ltd as to its fringe benefits tax liability for the year ended 31 March 2012.

  What amount of gift tax will she pay

what amount of gift tax will she pay? Evaluate net tax savings percentage as a family unit if Sean sells the land

  Calculate sem pty ltds taxable income

Indicate with explanations, sections of the Acts and relevant case law how the Revenue and Expense items (together with the Notes) in the company's accounts are treated for tax purposes.

  Record transactions in journal of gretta chung associates

Lump sum asset purchases, partial year depreciation, and impairments - Record transactions in journal of Gretta Chung Associates

  Evaluate the cost of a 20-guest afternoon picnic

Evaluate the cost of a 20-guest afternoon picnic and evaluate the cost of a 20-guest evening formal dinner.

  Calculate the capital gain under the indexation method

Calculate the capital gain under the indexation method and calculate the capital gain under the 50% discount method.

  Evaluate the capital gain under the indexation method

Calculate the capital gain under the indexation method and calculate the capital gain under the 50% discount method.

Free Assignment Quote

Assured A++ Grade

Get guaranteed satisfaction & time on delivery in every assignment order you paid with us! We ensure premium quality solution document along with free turntin report!

All rights reserved! Copyrights ©2019-2020 ExpertsMind IT Educational Pvt Ltd