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TAX 4001 Project 2 Due Date Handed in to class on November 5, 2014 Your assignment is to individually prepare a memorandum to the tax file (see Chapter 2, Figure 2-6, page 2-27 in the 2015 Edition of the text for an example). The relevant facts are Carol is a successful physician who owns 100 of her incorporated medical practice. She and her husband Dick are considering the purchase of a commercial office building located near the local community hospital. If they purchase the building, Carol would move her medical practice to the new location and rent space at an arms length price. The rent income that Carol and Dick receive will be available to absorb passive losses generated by other passive activities they own. The net effect of this arrangement is a reduction in their income tax liability. Will Carol and Dicks plan work Explain. Your memorandum should include the Facts, Tax Issue(s), Conclusion, and Analysis. Use the UCF library website to search a database (CCH Internet Tax Research Network, RIA Checkpoint, or LexisNexis Academic database can be used). Hint - you will find guidance from the following sources of tax law. These sources should provide you with adequate information to come to a definitive conclusion regarding whether or not Carol and Dick will achieve the results they are hoping for. You will find guidance from the regulations under Reg. 1.469-2. Locate the specific section of Reg. 1.469-2 that applies to this fact pattern, and be sure to cite this specific section in the memorandum. After you have located the section of the regulation that applies to this fact pattern, review the following court cases that are relevant to this issue to help you in your analysis and conclusion (be sure to cite all three in the memorandum) Fransen v. U.S., 98-2 USTC 50,776 Sidell v. Comm., 2000-2 USTC 50,751 Krukowski v. Comm., 2002-1 USTC 50,219 Your score on this assignment will be determined as follows Professional Format 5 Points Clearly Written 7 Points Identification of Issue 8 Points Citation of appropriate provisions 3 Points Citation of appropriate case law 2 Points Total 25 Points Y, dXiJ(x( I_TS 1EZBmU/xYy5g/GMGeD3Vqq8K)fw9 xrxwrTZaGy8IjbRcXI u3KGnD1NIBs
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