ACCT 580- Advanced Taxation

Research Exercise #5: Terminations

Instructions:

To complete this assignment, you need to use the CCH Tax Research Network, available on  the CWU Library network:

  1. You must be logged into the CWU network (click here for help).

  2. You should click on this link to the CCH tax service with your right mouse button and have the CCH service open in a new window. Then you can use the service to find the answers and the form below to submit your answers.

  3. To use the CCH Tax Research Network to answer these questions:

    -Click on the Enter button on the first web page  
    -Click on the Federal tab on the main page of the CCH Tax Research Network  
    -Select the appropriate CCH features/resources for the exercise.  

Purpose:

The purpose of this exercise is to introduce you to the use of CCH for the purpose of finding and interpreting:

  1. The sections of the Internal Revenue Code (IRC) related to the exchange of property for ownership interests in corporations and partnerships;

  2. The sections of the Internal Revenue Regulations (IRR) related to those sections; and

  3. Revenue rulings and court cases related to those sections.

Last Name:  

 First Name:  

 

CCH Search Section Document to find: Enter your answer:
Standard Federal Income Tax Reporter
1. According to §331(a), how does a taxpayer treat the amount realized in a corporate distribution in a complete liquidation?
2. How would any recognized gain or loss under §331 be classified?
3. According to §334(a), what is the recipient's basis in the property received in a corporate liquidation?
4. How did the taxpayer classify the liquidating distributions in the Cummins Diesel case (71-1 USTC ¶9276)?
5. How did the IRS classify the liquidating distributions in the Cummins Diesel case and why was it detrimental for the taxpayer?
     
Standard Federal Income Tax Reporter
6. How would any recognized gain or loss under §731 be classified?
7. According to §732(b), what is the recipient's basis in the property received in a partnership liquidation?
8. According to the example in §1.732-1, which asset in a liquidating distribution do you assign basis to first and now does that affect the recipient's basis in the partnership before additional distributions are made?
9. According to Rev. Rul. 55-68, 1955-1 CB 372, how does a partner calculate the holding period of partnership assets acquired by a purchase of partnership interests from the other partners?
10. Briefly explain how a 1999 Revenue Ruling used Rev. Rul. 55-68. (Use the Check Citator feature.)

    
When you select Submit, your answers will be submitted to a database for grading by me.
The confirmation page that opens will be the only confirmation that you receive.

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Ronald R. Tidd, Ph.D., CPA
509.963.2466
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