Exam 11: Communicating Research Results

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To effectively convey the results of a tax research project, the practitioner must:

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You are preparing for an audit with an IRS agent for an important client. Your research has uncovered several favorable rulings and court decisions. What are the key points that should guide you in evaluating sources of the law?

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In slides and other visual aids, fancy fonts and many colors should be used to create a more sophisticated presentation.

(True/False)
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Well-written case opinions typically provide a summary of the evolution of the pertinent tax law and a discussion of the parties' competing interpretations.

(True/False)
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Public speaking is an important part of the tax practitioner's professional life and can be an accurate predictor of success.

(True/False)
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By far the most common form of substantive communication between the tax professional and his or her client is a:

(Multiple Choice)
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The heart of tax research communication is:

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Which of the following statements is CORRECT with respect to conflicting tax laws?

(Multiple Choice)
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In client files, a practitioner should include all of the following types of underlying legal authority EXCEPT:

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The two major elements of a client file are:

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Other factors being equal, decisions of which of the following Circuit Courts should be given additional weight when evaluating sources?

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Identify five types of tax-related communications.

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All of the following statements are CORRECT with regard to the weight of authority of tax documents EXCEPT:

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Even if all of the judicial precedent supports a taxpayer's position, the court still may hold against the taxpayer.

(True/False)
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Amy and Frank got married and they have approached you seeking your views about the gift tax and income tax consequences on the following facts.??As per the prenuptial agreement, Amy gave to Frank $100,000 of appreciated stock on the morning of their wedding. Amy's basis in the stock was $35,000. Under the terms of the agreement, Frank surrendered all other marital rights and claims to Amy's assets in exchange for these securities. Both Frank and Amy are residents of Arizona.??The file memo you prepared contains the following legal conclusions, based on controlling authority:•IRC Section 2501 imposes a tax on the transfer of property by gift, not when it is received by the donee, but upon the transfer. The donor is taxed, not the donee.?•The Supreme Court has held that prenuptial transfers in relinquishment of marital rights are not adequate and full consideration for the transfer of property. So, the transfer is treated as a gift.?•Since the prenuptial agreement is enforceable only after the marriage, the transfer has not taken place until after the marriage occurred. Thus, the transfer is eligible for the gift tax marital deduction.?•Although the transaction resulted in a gift, no gift tax is imposed due to the application of the annual exclusion and the unlimited gift tax marital deduction.?•Neither party recognizes gross income upon release of the marital rights. Gross income does not include the value of property acquired by gift.?•The donee takes the donor's income tax basis in the transferred property.Based on the information provided above, draft a client letter to an unsophisticated client explaining the gift tax consequences and the income tax consequences of the stock transfer.

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Initial determinations of the facts of a tax issue are likely to be incomplete because:

(Multiple Choice)
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Which of the following statements is INCORRECT regarding letters to unsophisticated clients?

(Multiple Choice)
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Effective written business communication often makes use of which of the following guidelines?

(Multiple Choice)
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Identify the major elements of a client letter, and briefly discuss the difference between a letter to a sophisticated client and to an unsophisticated client.

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Tax-related communications can come in many forms, for example:

(Multiple Choice)
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