Tax Memo C

Instructions: This is an individual assignment. The memo should not exceed two pages and students should use the tax memo template provided. However, the answer should be a full 2 pages (double spaced, times new roman 12pt., 1-inch margins) Do not repeat the question in the answer. Each memo must include an explanation of the relevant code sections, regs and/or other relevant controlling authority such as case law. Don’t just cite the rules or cases, explain them and their application to the specific facts in the questions. Any memo with a similarity score exceeding 24% on Turnitin will be rejected subject to the professor’s review and sole discretion. AI % will be an F on the assignment

Questions:

1.Part 1: On January 1, 2020, Mark Z., an individual owned all of the stock of Mita Corporation with an adjusted basis of $2,000. During 2020 Mark Z. received distributions from Mita Corporation totaling $30,000, consisting of $10,000 in cash and listed securities having a basis in in Mita Corporation and a fair market value on the date distributed of $20,000. Mita Corporation’s taxable year is the calendar year. As of December 31, 2020, Mita Corporation had earnings and profits accumulated after February 28, 1913, in the amount of $26,000, and it had no earnings and profits and no deficit for 2020. What result to the shareholder under Section 301?

2.Part 2: The facts are the same as in Example 1 with the exceptions that the shareholder of Mita Corporation is Banana Corporation and that the securities which were distributed had an adjusted basis to Mita Corporation M of $15,000. The distribution received by Banana Corporation totals $25,000 consisting of $10,000 in cash and securities with an adjusted basis of $15,000. What result to the shareholder under Section 301?

3.An individual, H, his wife, W, his son, S, and his grandson (S’s son), G, own the 100 outstanding shares of stock of a corporation, each owning 25 shares. Apply the stock attribution rules and determine each individual’s interest in the corporation.

Tax Research Memo
Sample Format
Your Firm
Your Town and State
Date
Relevant Facts
This section should summarize the important facts of the research case. Only
include the relevant facts in a clear and concise manner.
Specific Issues
Identify the issue(s) and state the issue(s) in the form of a question.
Conclusions
Think of your conclusion as the “short” answer to your issue. The conclusion
section is the place to provide tax advice, recommend action(s) for the client to take,
or identify the need for additional information. There may not be a single “best”
alternative to the client’s issue so be sure to consider all applicable alternatives.
Support your conclusion by referencing back to the authority you discussed in the
discussion and analysis section.
Support
This section discusses the issue(s). Begin with the relevant code section(s).
Identify the code section, paraphrase what it says and then discus why it’s
important. Discussion of the relevant Treasury Regulations should follow. Identify the
regulation, paraphrase the important sections, and then address the importance of
the regulation given the facts.
The discussion
should continue by
reviewing relevant Treasury
pronouncements (Revenue Rulings, Revenue Procedures, Letter Rulings, etc.) and
cases. Be sure to include complete cite for each authority. Summarize the important
facts for the pronouncement/case and then compare the facts of the
pronouncement/case to the research facts. Discuss how the facts are similar or
different. Explain how each ruling or case supports or weakens the clients’ position.
Documentation is a very important part communicating tax research and all
statements or opinions should be substantiated with supporting cites. Supporting
cites should be to primary sources only except in rare or unusual situations.