Loading...

Messages

Proposals

Stuck in your homework and missing deadline? Get urgent help in $10/Page with 24 hours deadline

Get Urgent Writing Help In Your Essays, Assignments, Homeworks, Dissertation, Thesis Or Coursework & Achieve A+ Grades.

Privacy Guaranteed - 100% Plagiarism Free Writing - Free Turnitin Report - Professional And Experienced Writers - 24/7 Online Support

Concord instruments corporation, 67 tcm 3036, t.c. memo 1994-248

09/11/2020 Client: arwaabdullah Deadline: 3 days

M E M O R A N D U M

Tax Research #2

To: Student

From: Paula Partner

Date: November 1, 2011

Subject: Regis’s Stock Sale Dilemma

Last week I met with Regis Philman, a long-time client of mine. Regis inherited a large investment portfolio from his grandfather. The securities are held in street name by his brokerage firm, T.D. Tradehouse. Regis’s broker, Sam Waterson, has standing oral instruction from him on sales transactions to sell the shares with the highest cost basis first in any given transaction.

In October of 2010, Regis instructed Sam to sell 6,000 shares of Rippa Corp. Stock. Regis’s investment portfolio contains 15,000 shares of Rippa, which were purchased in several transactions over a three year period. At the end of each month, the brokerage firm provides Regis with a monthly statement that includes sales transactions. It does not identify the specific certificates transferred.

In filing his 2010 income tax return, Regis used the specific identification method to calculate the $75,000 recognized gain on the sale, consistent with the instructions he provided to Sam to sell the shares with the highest cost basis first. On audit of his 2010 return, the IRS has taken the position that under Reg. Section 1.1012-1(c)(3), Regis should have used the FIFO method to report the sale of the Rippa shares, resulting in a gain of $140,000. According to the IRS’s interpretation of the Regulations, Regis may not use the specific identification method (and must use the FIFO method) because the broker did not provide written confirmation of Regis’s sales instructions.

Please provide me with a reply memorandum with your research findings on the issue of whether Regis may use the specific identification method to identify the shares sold, even though he did not technically comply with Reg. Section 1.1012-1(c)(3). I have already done a preliminary research exercise and come across a Tax Court case which will be your exclusive source, in conjunction with Section 1.1012-1(c)(3), for finding your answer. I have provided the cite below.

Sources

Concord Instruments Corporation, 67 TCM 3036, T.C. Memo. 1994-248.

*See Section XI of the opinion: Gain on Sale of Stock.

Treasury Regulation: Section 1.1012-1(c)(3)

Homework is Completed By:

Writer Writer Name Amount Client Comments & Rating
Instant Homework Helper

ONLINE

Instant Homework Helper

$36

She helped me in last minute in a very reasonable price. She is a lifesaver, I got A+ grade in my homework, I will surely hire her again for my next assignments, Thumbs Up!

Order & Get This Solution Within 3 Hours in $25/Page

Custom Original Solution And Get A+ Grades

  • 100% Plagiarism Free
  • Proper APA/MLA/Harvard Referencing
  • Delivery in 3 Hours After Placing Order
  • Free Turnitin Report
  • Unlimited Revisions
  • Privacy Guaranteed

Order & Get This Solution Within 6 Hours in $20/Page

Custom Original Solution And Get A+ Grades

  • 100% Plagiarism Free
  • Proper APA/MLA/Harvard Referencing
  • Delivery in 6 Hours After Placing Order
  • Free Turnitin Report
  • Unlimited Revisions
  • Privacy Guaranteed

Order & Get This Solution Within 12 Hours in $15/Page

Custom Original Solution And Get A+ Grades

  • 100% Plagiarism Free
  • Proper APA/MLA/Harvard Referencing
  • Delivery in 12 Hours After Placing Order
  • Free Turnitin Report
  • Unlimited Revisions
  • Privacy Guaranteed

6 writers have sent their proposals to do this homework:

Buy Coursework Help
Quality Homework Helper
Custom Coursework Service
Finance Homework Help
Writer Writer Name Offer Chat
Buy Coursework Help

ONLINE

Buy Coursework Help

Hi dear, I am ready to do your homework in a reasonable price.

$62 Chat With Writer
Quality Homework Helper

ONLINE

Quality Homework Helper

Hi dear, I am ready to do your homework in a reasonable price.

$62 Chat With Writer
Custom Coursework Service

ONLINE

Custom Coursework Service

Hey, Hope you are doing great :) I have read your project description. I am a high qualified writer. I will surely assist you in writing paper in which i will be explaining and analyzing the formulation and implementation of the strategy of Nestle. I will cover all the points which you have mentioned in your project details. I have a clear idea of what you are looking for. The work will be done according to your expectations. I will provide you Turnitin report as well to check the similarity. I am familiar with APA, MLA, Harvard, Chicago and Turabian referencing styles. I have more than 5 years’ experience in technical and academic writing. Please message me to discuss further details. I will be glad to assist you out.

$55 Chat With Writer
Finance Homework Help

ONLINE

Finance Homework Help

I have a Master’s degree and experience of more than 5 years in this industry, I have worked on several similar projects of Research writing, Academic writing & Business writing and can deliver A+ quality writing even to Short Deadlines. I have successfully completed more than 2100+ projects on different websites for respective clients. I can generally write 10-15 pages daily. I am interested to hear more about the project and about the subject matter of the writing. I will deliver Premium quality work without Plagiarism at less price and time. Get quality work by awarding this project to me, I look forward to getting started for you as soon as possible. Thanks!

$55 Chat With Writer

Let our expert academic writers to help you in achieving a+ grades in your homework, assignment, quiz or exam.

Similar Homework Questions

Course weighted average to gpa curtin - MKTG201 Week 4 Midterm Exam - Biology 1 - What is fahrenheit 451 warning us about - Swms template master builders - Project human resource management pmbok - Nullity of a matrix maple - Nouns ending in i - Jcu lib guide referencing - Keyboard is an output device - Hrm599capstone assignment 2 - Shadow health esther park answer key - Publishers of a magazine wish to determine what proportion - Zappos case study pdf - How to make an atb online account - Ben and jerry's distribution channels - Helping skills facilitating exploration insight and action 4th edition - Fast moving consumer electronics - How to prepare oxygen in the laboratory - Ackademicks - Informative speech on stress and it’s effects with outline - Leadership Analysis - Geopolitical community assessment - Engineering ethics charles b fleddermann pdf - Who can do this please - Doug wade insurance consultant - Employee engagement project charter - Story with hidden meaning - Sexual health clinic kilmarnock - Oedipus killing laius quotes - Critical Thinking: Factor Endowment Theory - The adjusted trial balance for rowdy profits corporation - Grant Era and New South Assignment - Which molecule is nonpolar and has a symmetrical shape - Globe telecom number of subscribers - Finding z score on ti 83 - Calorimetry specific heat capacity of metals lab report - Focus questions a rose for emily answers - Medusa company allocates costs from the payroll department - Old testament character sketch bibl 104 - Econ 304 psu - ACCT 660 Project 3 BI - 800 words Essay (APA Origina) - Ayrtons antiseptic cream uk - Arbonne protein nutrition facts - Galen college of nursing syllabus - Stelrad radiator cover removal - Dmaic project report - Punctuated equilibrium model of team development - Brent staples why colleges shower students with a - Separation of the components of a mixture lab report answers - I need to complete my assinments for cert iv in disablity - Concept of spatial organization in psychology - Child abuse and/or neglect - Math homework - Christopher paul curtis the watsons go to birmingham - Worksheet 7.2 rates of reaction answers - Explain woodrow wilson's vision for peace after world war i - Exsum - Buys ballot law ppt - Perfume network of san ysidro california cosmetics & original cologne - Need residency project with PPT - Mid digital hair recessive or dominant - Legal, Ethical, and Risk Issues in Organizations - The combining form meaning childbirth is - Information overload can be reduced by course hero - Philosophy101 - Practical connection assignment - Post it notes on a marriage play - Family Engagement - Conservation of linear momentum lab - Threat hunting-- Research paper - Soap format - States of matter virtual lab - Mcdonalds franchise agreement example - S&s in chapter database - Discussion Post Aug 16 6pm.et - Wgu capstone business plan - Leccion 3 cultura el ultimo emperador inca completar - What is made of microtubules and microfilaments - The welcome table alice walker sparknotes - Cim certificate in professional marketing official module guide - Macquarie university windows 10 - W3 Discussion Question 1 - Max's maximum case study - When do i use an apostrophe - Briefly describe how supportive and interpersonal psychotherapies are similar - Year 3 french activities - Hydraulics 1 and 2 course - Power Point - Nancy drew pit of vipers summary - Issa sports nutrition case study - Course 2 chapter 9 probability answers - Jack michael motivating operations - Experiment 1 observation of mitosis in a plant cell - Calorimetry specific heat capacity of metals lab report - Analyzing foreign market entry strategies extending the internalization approach - The tale of the eloquent peasant sparknotes - Seyedeh fatemeh seyed modalal kar - Initiating the Project-6