Compare and contrast the constructive receipt doctrine and the
assignment of income doctrine. In what situations do these
doctrines apply? What tax planning strategies does each doctrine
limit?
1. Constructive
Receipt – Assignment of Income Doctrines
Please comment on the doctrines of constructive receipt and
assignment of income. What is each one all about? What do you think
the purpose is of each one, what perceived abuses are each designed
to counter?
2. Discharge of
Debt
Explain the rules for discharge of indebtedness income. When is
it taxable, and when isn’t it? Why? Do you think these rules make
sense?
Please comment on the doctrines of constructive receipt and
assignment of income. What is each one all about? What do you think
the purpose is of each one, what perceived abuses are each designed
to counter?
"Tax Implications"
Your client, Jack, has asked about the differences between the
constructive receipt doctrine and the claim of right doctrine.
Explain what each doctrine is by providing an example to help
Jack understand the differences.
Claim of right doctrine - judicial doctrine that states that
income has been realized if a taxpayer receives income and there
are no restrictions on the taxpayer's use of the income (for
example, the taxpayer does not have an obligation to repay the
amount)....
“The Tax Court erred in Crandall v. Commissioner. The
“substance-over-form” doctrine, not the constructive receipt
principle, should have controlled. The cash proceeds from the sale
of their Arizona property that were placed into escrow ($66,000) in
fact were never received by Mr. & Mrs. Crandall, even
momentarily. That fact should have resulted in a decision that they
correctly reported the sale and follow-on acquisition of the
California property as a good § 1031 LKE.”
Discuss.
Read Hornung v. Commissioner, 47 T.C. 428 (1967), which involves
the constructive receipt doctrine and how it was used to determine
the year of inclusion in taxable income. How does the constructive
receipt doctrine impact a cash-basis individual’s taxable income?
What factors could have resulted in a different determination?
Compare and Contrast Various Selling Models
The purpose of this assignment is to compare and contrast two or
more competing selling models. The basis for this paper will be The
Challenger Sale (Dixon and Adamson) versus Strategic Selling
(Miller & Heiman).
Provide an overview of both approaches. This overview should
include the theoretical basis, practical application, and general
steps or stages.
Take a position on which approach would be more
effective for managing customer accounts that would be
considered “Key...
Compare and Contrast Various Selling Models
The purpose of this assignment is to compare and contrast two or
more competing selling models. The basis for this paper will be The
Challenger Sale (Dixon and Adamson) versus Strategic Selling
(Miller & Heiman).
Provide an overview of both approaches. This overview should
include the theoretical basis, practical application, and general
steps or stages.
Take a position on which approach would be more
effective for managing customer accounts that would be
considered “Key...
Compare and contrast the contact situations of African Americans
and Irish immigrants. What were the key differences pointed out by
the author of the text? How are these differences reflected in the
current situations of both these groups