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27 Cards in this Set

  • Front
  • Back
Once formed a corporation must make certain elections
selecting tax year
selecting accounting methods
s corporations must generally use ___for its choice of tax year.
calendar year
form that you use to request approval for accouning period change
1128
Wich conditions mst be met
corporation files short period tax return for the year of change and annualizes invome when computing
files 12 month returns subsequently
closes its books as of the last day of the short period
if generates NOL may not carry back can carry forward
must not have changed tax years within last 48 months
must not have an interst in a pass through entity
Cannot be an S corporation, tzx exempt org or other spec corp
coporation not required to use accrual method if it meets ___ of the follwing conditions
qualified family farming operation
a qualified personal service corporation
if prior three year recipts do not total 3mil
s corporations
TWO
CORPORATE CAPITAL GAINS ARE TAXED AT THE ---- RATE
REGULAR CORPORATE TAX RATE
corporate NOL is
the excess of its deduction over its income
Passive losses apply to ___ and not to_____
individuals, partners, s corp shareholders, closely held C corporations, and PSCs

do not apply to widely held C corp
are considered to be business related and are deductible in full
casualty losses
if a corporation incurs a net captial loss it treats it how
it cannot deduct the net loss in the current year
a corporations capital losses can only offset captial gains.
a corporation must carry back a net captial loss as___ and offset captial gains in the __
If the loss is not completely absorbed as a carrkyback, the remainder
a short term captial loss to the tree previous tax year

earliest year possible

carries over as a short term capital loss for five years
section 291 staes
if a taxpayer sells sec 1250
a corporation must carry back a net captial loss as___ and offset captial gains in the __
If the loss is not completely absorbed as a carrkyback, the remainder
a short term captial loss to the tree previous tax year

earliest year possible

carries over as a short term capital loss for five years
section 291 staes
if a taxpayer sells sec 1250
SOURCES OF TAX LAW
LEGISLATION
INTERNAL REVENUE CODE
TREASURY REGULATIONS
ADMINISTRATIVE PRONOUNCEMENTS
JUDICIAL DECISIONS
TAX TREATIES
OTHER
LEGISLATIVE PROCESS
WAYS AND MEANS COMMITTEE
FULL HOUSE
SENATE FINANCE COMMITTEE
FULL SENATE
CONFERENCE COMMITTEE
FULL HOUSE AND SENATE
PRESIDENT SIGNS OR VETOES
INTERNAL REVENUE CODE
TITLE 26 OF US CODE
ORGANIZATION
TITLE
SUBTITLE
CHAPTER
SUBCHAPTER
PART
SUBPART
SECTION
TREASURY REGULATIONS
AUTHORITY DELEGATED TO IRS
TYPES
PROPOSED: NO WEIGHT
TEMPORARY
IMMEDIATE GUIDANCE
SAME AUTHORITY AS FINAL REGS.
FINAL
INTERPRETIVE
INTERPRET RELATED CODE SECTION
LESS AUTHORITY THAN IRC
LEGISLATIVE
ALMOST SAME AUTHORITY AS IRC
LEGISLATIVE REENACTMENT DOCTRINE
ADMINISTRATIVE PRONOUNCEMENTS
REVENUE RULINGS
MORE SPECIFIC THAN REGS.
LESS AUTHORITY THAN REGS.
REVENUE PROCEDURES
IRS GUIDANCE ON PROCEDURAL MATTERS
PRIVATE LETTER RULINGS
RESPONSES TO PARTICULAR TP QUESTIONS
ONLY AUTHORITY FOR SPECIFIC TP
JUDICIAL DECISIONS
OVERVIEW OF FEDERAL COURT SYST.
US TAX COURT
US DISTRICT COURT
US COURT OF FEDERAL CLAIMS
US COURT OF APPEALS (CIRCUITS)
US SUPREME COURT
PRECIDENTIAL VALUE OF VARIOUS DECISIONS
OVERVIEW OF COURTS
SUPREME COURT
COURT OF APPEALS FOR GEOGRAPHICAL JURISDICTION
US DISTRICT COURT
US TAX COURT
COURT OF APPEALS FOR FEDERAL CIRCUIT
US COURT OF FEDERAL CLAIMS
TAX COURT
DON’T PAY BEFORE LITIGATING
NO JURY TRIAL
REGULAR AND MEMORANDUM DECISIONS
SMALL CASES PROCEDURE
ACQUIESCENCE POLICY
REGULAR DECISIONS
FIRST TIME COURT HEARS
MEMORANDUM DECISIONS
FACTUAL VARIATIONS OF PRIOR CASES
SMALL CASE PROCEDURE
CASES LESS THAN 50K ELIGIBLE
LESS FORMAL THAN REGULAR TAX COURT
US DISTRICT COURTS
CAN HAVE JURY TRIAL
MUST PAY DEFICIENCY FIRST
UNREPORTED DECISIONS OCCUR
DECISIONS NOT OFFICIALLY REPORTED
PUBLISHED BY RIA AND CCH
COURT OF CLAIMS
NO JURY TRIAL
MUST PAY DEFICIENCY FIRST
APPEALABLE DECISIONS TO FEDERAL CIRCUIT