2-55

Tax Research, Practice, and Procedure

@Research Problem. What is the current

status of Rev. Rul. 57-82?

~esearch Problem. Code Sec. 303(b)(2)

(A) (ii) makes reference to two other Code
sections. What are they?

~ Research Problem. Which Rev. Rul. does

Rev. Rul. 76-74 supersede?
@Research Problem. What is the date of IRS

Letter Ruling 8302032?

~esearch Problem. On what date was Reg.

1.274-8 adopted?

67. Research Problem. What Code Section

immediately follows Code Sec. 280?
68. Research Problem. Refer to a citator and
locate the following case: New York Life

Insurance Co. v. Edwards.

a.
b.

What happened on appeal to the Court

of Appeals?
What happened on appeal to the
Supreme Court?

69. Research Problem. What Code sections

cover the standard deduction, trade or
business expenses, losses, medical expenses,
and moving expenses?
70. Research Problem. What two Code sections
are referred to in Code Sec. 56(f)(2)(F)(ii)(II)?
71. Research Problem. Refer to the Pennsylvania
Indemnity Co. case in a citator. What was
the disposition of the case on appeal to the
Supreme Court from the Court of Appeals?

~esearch Problem. What is the effective date

of Code Sec. 1031(f)?
76. Research Problem. A borrower is personally
liable on a real estate mortgage with an
outstanding balance of $1.5 million.
Borrower's basis in the property is $1 million
and the property has a current fair market
value of $1.2 million. The property is
repossessed by the bank.
a. If the borrower is insolvent both before
and after the repossession, what taxable
gain, if any, is recognized by borrower?
b. Does your answer to (a) change if the
borrower is not personally liable on the
mortgage (i.e., a nonrecourse debt)?
Why or why not?
77. Research Problem. Anthony Antunicci, a
Massachusetts lawyer, has tired of the long,
cold New England winters. He recently
spent three months in Florida where he took
a Florida bar review course which enabled
him to successfully pass the Florida bar
exam. He has since opened a second law
office in Coral Gables and plans to work in
that office from January through March each
year. His younger brother, Joey, will operate
their Boston office in his absence.
Can Anthony deduct the cost of the Florida
bar review course as an education expense
since he has already established himself in the
profession of being a lawyer by previously
passing the Massachusetts bar exam?
(Hint: to answer this question using CCH
Online, use the search term: (lawyer or
attorney) and (bar review course and
second state).)

@Research Problem. Reg. 1.212-l(n) refers

to two Code Sections. What are they?

73. Research Problem. Refer to Black's Law
Dictionary or a similar legal reference book
and ascertain the definition of the following
words or terms: annotated, certiorari,
remanded, dictum, acquiesced.
74. Research Problem. A taxpayer has a cellular
telephone, used 45 percent for business and
55 percent for personal use. Is the MACRS
depreciation method allowable?

78. Research Problem. Jane was notified by the

IRS that she should appear at the local IRS
district office with records supporting travel
expense deductions taken on her 2012 tax
return. Because she had to meet with some
clients, she did not appear at the IRS office,
nor did she bother to make an appointment
for an alternative time. To what penalty or
penalties could Jane be subject?