CH 01
CH 01
CH 01
1-35 Linda is correct in her assessment that the regular corporate form will not be a suitable vehicle for holding
her investment property. This option is not viable because losses will remain within the corporation for
possible future use against corporate income. Because she can qualify for the $25,000 exception to the
passive activity loss rules for actively managed rental realty, she will want the losses passed through to
her for use on her individual return.
5- Linda is also correct with respect to using an S corporation as a vehicle for holding her investment.
Although use of an S corporation would appear ideal because losses flow through to the shareholders, the
total amount of deductible losses allowed to her would be limited to the basis in her capital account
($40,000). Given the high rate of interest on her loan and the riskiness of her investment, her basis could
be reduced to zero within several years.
5- Linda’s third option is interesting and, according to the Supreme Court case of Bollinger, viable. If
the corporation can be formed as a regular corporation and be treated for Federal income purposes as
Linda’s agent, all losses will pass through to her and may be used against her total basis in the investment
of $240,000. Her basis in her investment includes the nonrecourse note because the investment in realty
was acquired with a nonrecourse loan from a qualified lender [see § 465 (b)(6)].
5- There are, however, a number of precautions for ensuring acceptability of this third option by the IRS.
According to the Supreme Court in Bollinger, the corporate-agent relationship is established if (1) the fact
that the corporation is acting as agent for its shareholders with respect to a particular asset is set forth in a
written agreement at the time the asset is acquired, (2) the corporation functions as the agent and not the
principal with respect to the asset for all purposes, and (3) the corporation is held out as the agent and not
the principal in all dealings with third parties relating to the asset.
5- If Linda follows the Supreme Court guidelines, it is very likely she will obtain her objectives. What
specifically can she do? The Bollinger case provides a model of specific steps to take to establish an
agency relationship. Bollinger formed an agency relationship with his corporation and stipulated that the
corporation was formed solely to obtain financing, that the corporation was not liable for maintenance of
the property or for repayment of any promissory notes, and that Bollinger would indemnify and hold the
corporation harmless from any liability it might sustain as his agent.
Note: Solutions to tax return problems 1-33 and 1-34 are located after the test bank and answers.
1-1
H Chapter One H
TEST BANK
True or False
1. The proprietorship uses gross ordinary income as the basis for calculating any self-employment tax
due.
3. In transactions between the partners and the partnership, the parties are generally treated like
unrelated parties.
4. Section 11 of the Code imposes a tax on all corporations, including nonprofit organizations.
6. If an individual taxpayer creates a legal corporation under state law, the government (i.e., the IRS)
cannot disregard the entity and tax the individual taxpayer on the income.
7. Although recognized as partnerships under state law, certain partnerships are treated and taxed as
corporations for Federal income tax purposes.
8. All bad debts of a corporation are treated as business rather than nonbusiness bad debts.
10. In computing a corporation’s limitation on the dividends-received deduction, its taxable income is
determined without the deductions for dividends received, net operating loss carryovers, and capital
loss carrybacks.
11. Where a dividends-received deduction adds to or creates a net operating loss, the taxable income
limitation decreases from 70 percent to 34 percent.
12. At its election, a corporation can either deduct all organizational costs paid during the current year or
amortize the expenditures over a period not less than 180 months.
13. Because organizational costs are assets with indefinite lives (i.e., they have value for the life of the
corporation), they may not be expensed or amortized.
14. Organizational expenses incurred by an accrual basis corporation in its first year of existence but paid
in a later year will not qualify for amortization.
1-2
Test Bank 1-3
15. If an accrual basis corporation incurs an additional expense in setting up its accounting system after
the close of its first tax year but before the due date of its initial return, the expense qualifies as an
organizational expense and may be amortized.
16. A corporation is not allowed a dividends-received deduction in computing its net operating loss for
any given year.
17. A corporation’s annual charitable contribution deduction is limited to 10 percent of its taxable
income without reduction for charitable contributions, the dividends-received deduction, net
operating loss carrybacks, and capital loss carrybacks.
18. In planning for its annual charitable contributions, a corporation should take into account any net
operating loss or capital loss carryforwards since such items reduce the corporation’s taxable income
base for purposes of the annual deduction limitation.
19. Unlike individuals, corporations with excess capital losses in the current year are allowed to carry
these losses back five years and forward three years to offset capital gains in the carryback or
carryforward years.
20. A corporation may be required to recapture (as ordinary income) a greater portion of its gain on the
sale of depreciable real property than would an individual taxpayer.
21. An accrual basis corporation must use the cash method in claiming deductions for amounts paid to its
cash basis sole shareholder.
22. The 2009 Federal income tax rate for a calendar year corporation with taxable income of $335,000
up to $10 million is 34 percent.
24. A personal service corporation with taxable income of $10,000 for its 2009 calendar year will have a
regular Federal income tax liability of $3,500 before credits or prepayments.
25. A corporation with alternative minimum taxable income of $20,000 will be subject to an alternative
minimum tax of $4,000.
Multiple Choice
The dividends were received from a taxable domestic corporation in which T owns 15 percent of the stock
(not debt-financed). What is T Corporation’s dividends-received deduction for 2009?
a. $0
b. $15,400
c. $21,000
d. $24,500
e. $35,000
31. Corporations A, B, and C are taxable domestic corporations. All are members of an affiliated group.
Corporation A pays a $50,000 dividend to B and a $50,000 dividend to C. Corporations B and C are each
entitled to a dividends-received deduction of
a. $35,000.
b. $40,000, subject to the taxable income limitation.
c. $50,000.
d. $0.
e. None of the above.
Test Bank 1-5
32. New Corporation was organized and began active business on January 7, 2009. New incurred the following
expenses in connection with opening the business:
Assuming New Corporation adopts a calendar year for tax purposes, what is the maximum amount of
organizational expenses that may be deducted on the corporation’s initial tax return?
a. $0
b. $
c. $1,800
d. $1,975
33. A newly formed corporation elected to use a fiscal year ending June 30. On July 17, 2009, the corporation
began business and incurred $8,000 of qualified organizational expenses. Assuming that the corporation
properly elected to deduct/amortize these costs, what is the amount of organization expenses that it should
deduct on its tax return for the fiscal year ending June 30, 2010.
a. $0
b. $533
c. $5,000
d. $5,200
34. X Corporation, which files its tax return on a cash basis, incurred organizational costs (not to a related party)
of $5,000 during its first year. $1,875 of these expenses were paid in the fourth month after the close of its
taxable year. What is the maximum deduction the corporation is entitled to claim on its first tax return if that
tax return is for a period of 111=2 months and a proper election is made?
a. $0, because organizational costs have an indefinite life.
b. $200.
c. $3,125.
d. $5,000.
35. The charitable deduction for a corporation is limited both by type of property contributed and an annual
maximum amount. Which of the following is a false statement?
a. An accrual basis corporation may deduct contributions authorized during the tax year but actually paid
within two and one-half months after the close of the tax year.
b. The annual maximum amount of charitable deduction for a corporation is 10 percent of taxable income
calculated before certain deductions.
c. Generally, a corporation is allowed a deduction for the fair market value of capital gain and ordinary
income property.
d. In certain cases where a corporation donates capital gain property, the allowable deduction is limited to
the fair market value, reduced by the amount of unrealized appreciation (i.e., the deduction is limited to
the property’s adjusted basis).
1-6 Income Taxation of Corporations
36. Which one of the following statements is true for a regular corporation?
a. Charitable contributions in excess of the 10 percent limitation may be carried over to subsequent years
indefinitely.
b. A contribution carryover is allowed as a deduction even if it increases a net operating loss.
c. Charitable contributions in excess of the 10 percent limitation may, subject to limitations, be carried
back to each of the preceding three years.
d. Charitable contributions in excess of the 10 percent limitation may, subject to limitations, be carried
over to each of the following five years.
e. Subject to the 10 percent limitation, a carryover of excess contributions is used before the contributions
made in the carryover year.
37. T Corporation’s taxable income for 2009 was $100,000, computed by erroneously deducting the
corporation’s total charitable contributions of $12,000. The correct contribution deduction for T Corporation
is
a. $6,000
b. $8,800
c. $10,000
d. $11,200
e. $12,000
38. During its first year of operation, K Corporation had a gross profit from operations of $180,000 and
deductions of $250,000 before considering its dividend income or dividends-received deduction. K received
dividends of $50,000 from a taxable domestic corporation in which K owned 4.5 percent of the stock.
Assuming its ownership of the dividend-paying corporation’s stock is not debt financed, what is K
Corporation’s net operating loss for the year?
a. $20,000
b. $49,000
c. $55,000
d. $65,000
e. $70,000
39. Z Corporation had 2009 taxable income of $600,000 before considering the following:
The equipment sold at a gain originally cost $150,000, and $90,000 of depreciation had been claimed. What
is Z Corporation’s taxable income for 2009?
a. $618,000
b. $633,000
c. $647,000
d. $671,000
e. $685,000
40. Which of the following is different for corporations than it is for individuals?
a. The definition of capital asset.
b. The determination of holding period for capital assets.
c. The capital gain and loss netting process.
d. The treatment of capital loss carryovers.
Test Bank 1-7
41. T Corporation sold a commercial building for $200,000 on January 2, 2009 (purchased for $150,000 on
December 16, 2004). The building was depreciated using the straight-line method, and depreciation in the
amount of $20,000 has been taken. The amount and nature of the gain upon sale is
a. $70,000 § 1231 gain.
b. $50,000 § 1231 gain and $20,000 ordinary income.
c. $66,000 § 1231 gain and $4,000 ordinary income.
d. $70,000 ordinary income.
e. None of the above.
42. J is a 60 percent shareholder in the JS Corporation. In 2006, he sold property to the corporation for $60,000
(basis in his hands of $70,000). In 2009, the corporation sold the property for $65,000 to an unrelated party.
The amount of gain or loss the JS Corporation must recognize in 2009 is
a. $(5,000)
b. $0
c. $5,000
d. $10,000
43. Which of the following is a false statement regarding transactions between corporations and their
shareholders?
a. Corporations are not allowed to deduct a loss incurred in a transaction between related parties.
b. A shareholder owning 50 percent of a corporation’s outstanding stock is a related party according to the
general rule.
c. In the case of a personal service corporation, any employer-owner that owns any of the corporation’s
stock is a related party under certain conditions.
d. The sale of property at a gain between a corporation and its controlling shareholders is not affected by
the related parties rules.
44. Z Corporation’s 2009 calendar year taxable income is $2,000,000. The corporation’s 2009 Federal income
tax liability before credits and prepayments is
a. $680,000
b. $769,460
c. $899,740
d. $920,000
e. $1,020,000
45. A regular corporation and a personal service corporation each have taxable income of $20,000 for the 2009
calendar year. Ignoring the alternative minimum tax provisions, which one of the following statements is
true regarding the Federal income tax liabilities of these two corporations?
a. Both corporations will have the same tax liability before credits or prepayments.
b. The regular corporation will have a slightly lower tax liability before credits or prepayments.
c. The personal service corporation will have a slightly lower tax liability before credits or prepayments.
d. The regular corporation’s tax liability will be exactly $2,000 less than the tax liability of the personal
service corporation.
e. The regular corporation’s tax liability will be less than half that of the personal service corporation.
46. The principal activity of several corporations is shown below. Which of the following could not be classified
as a personal service corporation?
a. Engineering
b. Actuarial science
c. Performing arts
d. Manufacture of personal computers
e. Veterinary medicine
1-8 Income Taxation of Corporations
47. Two personal service corporations (PSCs) are properly determined to be a brother-sister controlled group.
Corporation A has taxable income of $75,000, and Corporation B has a loss of $50,000. Which of the
following is a true statement?
a. Corporation A may owe $13,750 in Federal income taxes before credits, depending on lower tax rate
bracket allocation.
b. Corporations A and B are permitted to allocate the use of the lower tax rates in any manner they so
elect, provided that both A and B agree to the allocation.
c. The corporations will pay a combined tax on the first $25,000 of taxable income at 15 percent, or
$3,750.
d. Corporation A will owe $26,250 in taxes before credits.
e. a and b above.
48. A brother-sister controlled group consists of two or more corporations connected through the stock
ownership of certain types of shareholders, including
a. regular corporations, but not S corporations.
b. S corporations, but not regular corporations.
c. individuals and estates, but not trusts.
d. individuals, estates, or trusts.
e. regular or S personal service corporations.
49. Two or more corporations owned by five or fewer noncorporate shareholders, who collectively own more
than 50 percent of the stock of each corporation, would best describe
a. brother-sister controlled group.
b. association.
c. S corporation pending proper election.
d. parent-subsidiary controlled group.
e. controlled group.
50. Which of the following statements about the corporate alternative minimum tax is false?
a. Generally, the tax is computed at a 20 percent rate on alternative minimum taxable income (AMTI) in
excess of $40,000.
b. Alternative minimum tax (AMT) liability exists only if the corporation’s tentative AMT (reduced by
allowable credits) exceeds its regular tax liability for the year. The difference is called the AMT.
c. AMT adjustments simply reflect timing differences between allowed deductions and gain recognition
reporting methods for regular tax purposes and for AMT purposes.
d. AMT preference items act only to increase tentative AMTI.
e. The $40,000 exemption is reduced by 25 percent of the amount of AMTI in excess of $150,000 and is
completely phased out for AMT in excess of $250,000.
51. B Corporation reported taxable income in 2009 of $1 million. Additional information concerning B’s 2009
tax return is as follows:
59. Large Corporation, with over $1 million in taxable income for each of the last several years, paid estimated
tax payments of $30,000 each quarter for the current year. The actual tax liability for the current year is
$160,000; last year’s tax liability was $145,000. Income is earned evenly throughout the year. What is the
quarterly amount that may be subject to the underestimation penalty?
a. There is no underpayment amount subject to penalty.
b. $6,250
c. $10,000
d. $40,000
60. X Corporation determines it cannot meet the filing deadline for Form 1120 (U.S. Corporation Income Tax
Return) and files an extension on Form 7004. Which of the following is not true?
a. The corporation claims an automatic six-month extension of time to file the tax return and to pay the tax
due.
b. With permission of the IRS, corporations may be granted an additional three-month extension to submit
Form 1120.
c. The corporation extension (Form 7004) must be filed on or before the 15th day of the 3rd month
following the close of the taxable year.
d. None; all are true.
H Chapter One H
True or False
1. False. Net ordinary income is the basis for calculating any self-employment tax due for a proprietorship
(See p. 1-2.)
2. True. The tax return of the S corporation is generally a reporting vehicle that details the distribution of
the income and expenses to the shareholders. Tax liability is determined at the shareholder level. (See
p. 1-4.)
3. True. The partners and the partnership are generally treated as unrelated. Remember that tax liability is
determined at the partner level. (See p. 1-3.)
4. True. Although § 11 requires all corporations to pay tax, other provisions in the law specifically exempt
certain types of corporations from taxation. [See p. 1-4 and § 882(a).]
6. False. It is the Internal Revenue Code that will be applied in determining the status of an entity for tax
purposes. (See pp. 1-5 and 1-6 and Reg. § 301.7701-2.)
7. True. Unless specifically exempted from the rule, a publicly traded partnership organized after December
17, 1987 will be treated and taxed as a corporation. (See p. 1-6.)
8. True. Because all activities of a corporation are considered business activities, all bad debts are
considered to be business bad debts. (See p. 1-8 and § 166.)
10. True. The 70 percent dividends-received deduction may not exceed 70 percent of the corporation’s taxable
income as defined in § 246(b). (See Exhibit 1-3, Examples 4 through 6, and pp. 1-9 through 1-14.)
11. False. There is no taxable income limitation where a dividends-received deduction adds to or creates a
net operating loss. [See Exhibit 1-3, Examples 6 and 14, pp. 1-9 and 1-16, and § 246(b)(2).]
12. False. In general, organizational expenses of a corporation may not be deducted in full in the
corporation’s first tax year. However, a corporation may elect to deduct organizational costs in a special
way—$5,000 during the first tax year with the remainder amortized over 180 months. Thus, only those
corporations with expenses of $5,000 or less can expense the full amount in the current tax year. Note
that the $5,000 amount is subject to a phase-out when organizational expenses exceed $50,000. (See pp.
1-14 and 1-15.)
1-11
1-12 Income Taxation of Corporations
13. False. In general, organizational expenses of a corporation may not be deducted in full in the
corporation’s first tax year. However, a corporation may elect to deduct organizational costs in a special
way—$5,000 during the first tax year with the remainder amortized over 180 months. Thus, only those
corporations with expenses of $5,000 or less can expense the full amount in the current tax year. Note
that the $5,000 amount is subject to a phase-out when organizational expenses exceed $50,000. (See
p. 1-14 and § 248.)
14. False. Neither the taxable year of actual payment nor the corporation’s method of accounting (i.e., cash
or accrual) affect the qualification of organizational expenses. As long as the expenses are incurred
during the corporation’s first tax year, they qualify for amortization. (See p. 1-13 and § 248.)
15. False. Whether the corporation is a cash basis or accrual basis taxpayer is irrelevant. Only those
organizational expenses incurred by the corporation before the end of its first taxable year will qualify
for § 248. (See p. 1-14 and § 248.)
16. False. In computing a corporation’s net operating loss for any given year, the dividends-received
deduction is not limited to taxable income. Thus, the dividends-received deduction can create or increase
a corporation’s net operating loss for any given year. [See Exhibit 1-3, Examples 6 and 14, pp. 1-9
and 1-16, and § 246(b)(2).]
17. True. The annual limitation is 10 percent of taxable income determined without reduction for charitable
contributions, the dividends-received deduction, net operating loss carrybacks, and capital loss
carrybacks. [See pp. 1-18 and 1-19 and § 170(b)(2).]
18. True. Only net operating loss and capital loss carrybacks are ignored in computing a corporation’s
taxable income base for purposes of the annual limitation. (See p. 1-18.)
19. False. The carryback period is three years and the carryforward period is five years. (See Example 19 and
p. 1-19.)
20. True. A corporation must treat as ordinary income 20 percent of any § 1231 gain that would have been
ordinary income if § 1245 rather than § 1250 applied to the sale of certain depreciable realty. (See
Example 21, pp. 1-21 and 1-22, and § 291.)
22. True. A regular corporation is subject to a 5 percent surtax on all income in excess of $100,000 until the
benefit of the graduated corporate income tax rate structure is eliminated. The elimination of the benefits
of the lower corporate tax rates occurs when taxable income exceeds $335,000 (up to $10 million, at
which point the marginal rate increases to 35 percent). (See Example 22 and pp. 1-23 and 1-24)
23. False. Because only one of the shareholders of Corporation A owns stock in both corporations, the total
lowest identical ownership is only 10%. Therefore, a brother-sister controlled group does not exist. (See
Examples 28 and 29 and pp. 1-27 through 1-30.)
24. True. A personal service corporation (PSC) is not allowed to use the graduated corporate tax rates.
Instead, a PSC is subject to a flat tax rate of 35 percent, and its tax liability before credits or prepayments
would be $3,500 ($10,000 taxable income 35%). (See p. 1-25.)
25. False. A corporation is subject to the AMT only to the extent it exceeds the corporation’s regular tax.
More importantly here, because a corporation is entitled to a $40,000 exemption, this corporation would
not be subject to the AMT. (See Exhibit 1-8 and p. 1-31.)
Solutions to Test Bank 1-13
Multiple Choice
26. d. While a corporation is allowed to deduct a portion of qualifying dividends received from taxable
domestic corporations, there currently is no deduction for dividends paid to shareholders. (See p. 1-9.)
27. b. The ability to sue or be sued is not one of the corporate characteristics. (See p. 1-5.)
28. d. Corporations and individuals are subject to the same rules regarding depreciation deductions.
Corporations are subject to the possibility of additional depreciation recapture (i.e., § 291), while
individuals are not. Corporations are more limited in their charitable contribution deductions than
individuals, and corporations are not allowed to deduct capital losses against ordinary income (i.e., a
capital loss deduction). Finally, all bad debts of a corporation are considered to be business bad debts.
[See Examples 15 through 21, pp. 1-17 through 1-22, and §§ 291 and 170(b)(2).]
31. c. Members of an affiliated group are allowed to deduct 100 percent of the dividends that are received from
another member of the same group. A group of organizations is considered affiliated when at least 80
percent of the stock of each corporation is owned by other members of the group. [See p. 1-9 and
§§ 243(a)(3), 243(b)(5), and 1504.]
32. c. All of the expenses except the printing cost for stock certificates qualify as organizational expenses
($750 + $100 + $250 + $300 + $400 = $1,800 total). If New Corporation makes the election on a timely
filed return (plus extensions), it will be allowed to deduct the full amount in 2009. (See Example 11 and
pp. 1-14 and 1-15.)
33. d. Because the fiscal year ending June 30, 2010 has 12 full months, the allowed deduction is $5,200
[$5,000 + $200 ($3,000/180 = $16.67 per month 12 months)]. (See Example 12 and pp. 1-14 and 1-15.)
34. d. Neither the taxable year of the actual payment nor the corporation’s method of accounting affect the
calculation. (See Example 11, and pp. 1-14 and 1-15.)
35. c. The charitable deductions for ordinary income property generally may not exceed the corporation’s basis
in the property. (See pp. 1-17 and 1-18.)
1-14 Income Taxation of Corporations
36. d. Excess charitable contributions may be carried over to each of the succeeding five years, subject to
certain limitations. Since (1) the carryover period is limited to five years, (2) a charitable contribution
deduction is allowed only if the corporation has taxable income, (3) excess contributions cannot be
carried back, and (4) contributions made in the carryover year must be deducted before considering any
carryovers, only answer d is true. (See Examples 18 and 19 and pp. 1-18 and 1-19.)
37. d. Because the charitable contributions were erroneously deducted in full to arrive at an incorrect taxable
income number of $100,000, the first thing that must be done is to add back the $12,000 of deductions.
Thus, taxable income before the charitable contribution deduction is correctly $112,000. T Corporation’s
correct contribution deduction, therefore, is limited to $11,200 [($100,000 + $12,000 = $112,000 correct
taxable income before deduction) 10%]. The remaining $800 of charitable contributions must be
carried forward. (See Examples 18 and 19 and pp. 1-18 and 1-19.)
*Recall that a corporation’s dividends-received deduction is not subject to the taxable income
limitation if it adds to, or creates, a net operating loss for the year.
Under § 1250, there is no depreciation recapture. If § 1245 depreciation recapture applied to this sale,
gain would be ordinary income to the extent of depreciation taken ($20,000), and the remainder would be
taxed as § 1231 gain ($50,000). The § 291 depreciation recapture calculation is
Therefore, of the $70,000 total gain, $4,000 is ordinary and the remainder ($66,000) is § 1231 gain. (See
Example 21 and pp. 1-21 and 1-22.)
42. b. Under § 267, J was not allowed to recognize his loss of $10,000 in 2006 (J was a greater than 50%
shareholder in the JS Corporation). This loss may be carried over and used to offset gain when the related
party sells the property in a taxable transaction to an unrelated party. Therefore, the corporation’s realized
gain of $5,000 ($65,000 sales price less its $60,000 basis) is not recognized. Note, however, that the
suspended loss may not be used to create a recognized loss in the hands of the corporation. As a result,
$5,000 of the loss disappears. (See p. 1-20.)
43. b. With respect to the matching of income and deduction, a related party is any person owning directly or
indirectly more than 50 percent of the corporation’s outstanding stock. (See p. 1-22.)
44. a. The correct amount is $680,000 ($2,000,000 34%). Because Z Corporation’s taxable income exceeds
$335,000, it is taxed at the flat rate of 34 percent. (See Example 24 and pp. 1-23 and 1-24.)
45. e. A regular corporation’s tax on $20,000 of taxable income will be $3,000 ($20,000 15%). A personal
service corporation (PSC) is not allowed to use the lower corporate tax rates. Instead, a PSC is subject to
a flat rate of 35 percent. Consequently, the PSC’s tax on $20,000 of income will be $7,000 ($20,000
35%). (See pp. 1-23 and 1-24.)
46. d. The manufacture of personal computers is not specifically included in the definition of a personal service
corporation. [See p. 1-25 and § 448(d)(2).]
47. d. Congress denied the benefits of the lower tax rates to personal service corporations for taxable years after
1987 (Revenue Act of 1987). As a result, the taxable income of a PSC is subject to a flat rate of 35
percent. [See p. 1-25 and § 11(b)(2).]
48. d. A brother-sister controlled group consists of two or more corporations connected through the stock
ownership of certain noncorporate shareholders—individuals, estates, or trusts. (See p. 1-27.)
49. a. This is a description of the brother-sister type of controlled group. [See p. 1-27 and § 1563(a).]
1-16 Income Taxation of Corporations
50. e. The phaseout of the $40,000 exemption occurs at $310,000, not at $250,000. $40,000 ¡ 25% = $160,000;
$160,000 + $150,000 = $310,000. [See p. 1-30 and § 55(d)(3)(A).]
51. a. First, calculate the adjusted current earnings (ACE) adjustment. This is $600,000 [($2 million ACE less
$1.2 million AMTI) 75%]. This results in AMTI of $1.8 million ($1.2 million tentative AMTI +
$600,000). Then calculate the tentative AMT. This equals $360,000 ($1.8 million 20% AMT rate).
Note that the exemption is fully phased out when AMTI exceeds $310,000. Finally, calculate the regular
tax of $340,000 ($1 million taxable income 34% rate). Because the tentative AMT exceeds the regular
tax, the AMT is $20,000 ($360,000 $340,000). (See Example 35 and p. 1-33.)
52. b. Answers a, c, and d are the three basic exceptions to the general rule that denies the use of the cash
method of accounting for tax purposes to most corporations. (See p. 1-35.)
53. b. A personal service corporation must use a calendar year unless it can satisfy IRS requirements that there
is a business purpose for a fiscal year. [See p. 1-34, and § 441(I).]
54. b. Net capital losses are not currently deductible for Federal income tax purposes. The other items are all
subtractions from income per books. (See Example 37 and pp. 1-35 and 1-36.)
55. b. Schedule M-2 reconciles book opening and closing retained earnings—using accounting rather than tax
data. (See Example 39, and p. 1-39.)
56. a. The corporate taxpayer is required to file its tax return by March 15. [See p. 1-43 and § 6072(b).]
57. e. All are true statements concerning the obligation of a corporation to make estimated tax payments. (See
pp. 1-43 and 1-44.)
58. b. A ‘‘large’’ corporation is not allowed to use this exception except for its first installment of the taxable
year. (See p. 1-44.)
59. c. Large Corporation was required to pay $40,000 each quarter ($160,000/4 quarters 100%). Because
Large paid only $30,000 each quarter, the quarterly underpayment is $10,000. Large may not, except for
its first quarterly installment, base its payments on last year’s tax liability (it is a ‘‘large’’ corporation) and
may not use the annualization method (income is earned evenly). (See Example 35 and pp. 1-43 and
1-44.)
60. a. Form 7004 allows a corporation a six-month extension of time to file—not of time to pay the tax. Any tax
balance due must be paid with the extension. (See p. 1-43.)
H Chapter One H
X Corporation had the following items of income, expense, gain, loss, credit and prepayment for its 2009 calendar
year. X Corporation files Form 1120 using a calendar year. The figures shown below were prepared by
X Corporation’s controller using the accrual method of accounting.
1-17
1-18 Income Taxation of Corporations
COMPREHENSIVE PROBLEMS
a. Deduction for dividends received from less than 20% owned corporation, if any
b. Deduction for dividends received from Y corporation, if any
c. Deduction for dividends paid to Y corporation, if any
Note: Taxable income for the charitable deduction is figured without reduction for charitable
contributions, the dividends-received deduction, net operating loss carrybacks, or capital loss
carrybacks.
Because the $75,000 of actual contributions exceed this limit, the 2009 contribution deduction
allowed for taxes is $50,300.
d. Because current year contributions are used first for deduction purposes, the contribution carryover
from 2008 to 2010 remains the same, $20,000.
Note: There is no effect on taxable income for 2009 from capital gains.
3. a. Because this stock was held for less than 46 days, there is no dividends-received deduction.
b. X and Y Corporations qualify as affiliated corporations since each owns 80% or more of the stock of
the other. A 100% dividends-received deduction is allowed = $15,000.
c. There is no deduction for dividends paid.
1-20 Income Taxation of Corporations
Because all four estimated tax payments ($36,000 each) were made timely and in equal amounts, it is
evident at this point that no estimated tax underpayment exists.
$142,318 4 = $35,580
Each of the four estimated tax payments exceeded the amount due.
1-33 Form 1120 is shown on the following pages. Note that the underpayment tax penalty rate used in this
solution is assumed to be 6 percent. The actual penalty rate may be different.
1-21
1-22 Income Taxation of Corporations
20 08
Form For calendar year 2008 or tax year beginning , 2008, ending , 20
Department of the Treasury
Internal Revenue Service See separate instructions.
A Check if: Name B Employer identification number
1a Consolidated return
(attach Form 851) . Use IRS
label.
The Bike Shop 75 4476243
b Life/nonlife consoli- Number, street, and room or suite no. If a P.O. box, see instructions. C Date incorporated
Otherwise,
dated return .
2 Personal holding co.
. .
print or 1234 Wheeling Drive 05/01/1992
(attach Sch. PH) . . type. City or town, state, and ZIP code D Total assets (see instructions)
3 Personal service corp.
(see instructions) . .
Cincinnati OH 45202 $ 1,984,000.
4 Schedule M-3 attached E Check if: (1) Initial return (2) Final return (3) Name change (4) Address change
1a Gross receipts or sales 2,100,000. b Less returns and allowances c Bal 1c 2,100,000.
2 Cost of goods sold (Schedule A, line 8) . . . . . . . . . . . . . . . . . . . . . 2 715,000.
3 Gross profit. Subtract line 2 from line 1c . . . . . . . . . . . . . . . . . . . . . 3 1,385,000.
4 Dividends (Schedule C, line 19) . . . . . . . . . . . . . . . . . . . . . . . 4 5,000.
5 Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 10,000.
6 Gross rents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6
7 Gross royalties . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7
8 Capital gain net income (attach Schedule D (Form 1120)) . . . . . . . . . . . . . . . . 8
9 Net gain or (loss) from Form 4797, Part II, line 17 (attach Form 4797) . . . . . . . . . . . . 9
10 Other income (see instructions—attach schedule) . . . . . . . . . . . . . . . . . . 10
11 Total income. Add lines 3 through 10 . . . . . . . . . . . . . . . . . . . . 11 1,400,000.
12 Compensation of officers (Schedule E, line 4) . . . . . . . . . . . . . . . . . . 12 210,000.
13 Salaries and wages (less employment credits) . . . . . . . . . . . . . . . . . . . 13 265,000.
14 Repairs and maintenance . . . . . . . . . . . . . . . . . . . . . . . . . 14 20,000.
15 Bad debts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 1,000.
16 Rents . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16
17 Taxes and licenses . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 50,000.
18 Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 18 14,000.
19 Charitable contributions . . . . . . . . . . . . . . . . . . . . . . . . . . 19 60,000.
20 Depreciation from Form 4562 not claimed on Schedule A or elsewhere on return (attach Form 4562) . . . 20 50,000.
21 Depletion . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21
22 Advertising . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 22 14,000.
23 Pension, profit-sharing, etc., plans . . . . . . . . . . . . . . . . . . . . . . 23
24 Employee benefit programs . . . . . . . . . . . . . . . . . . . . . . . . 24
25 Domestic production activities deduction (attach Form 8903) . . . . . . . . . . . . . . . 25
26 Other deductions (attach schedule) .Meals. and. .entertainment
. . . .(50%)
. . . . . . . . . . . . . . 26 5,000.
27 Total deductions. Add lines 12 through 26 . . . . . . . . . . . . . . . . . . . 27 689,000.
28 Taxable income before net operating loss deduction and special deductions. Subtract line 27 from line 11 . . 28 711,000.
29 Less: a Net operating loss deduction (see instructions) . . . . . . . 29a
b Special deductions (Schedule C, line 20) . . . . . . . . . 29b 3,500. 29c 3,500.
30 Taxable income. Subtract line 29c from line 28 (see instructions) . . . . . . . . . . . . . 30 707,500.
31 Total tax (Schedule J, line 10) . . . . . . . . . . . . . . . . . . . . . . . . 31 240,550.
32a 2007 overpayment credited to 2008 . . 32a
b 2008 estimated tax payments . . . . 32b 150,000.
c 2008 refund applied for on Form 4466 . . . 32c ( ) d Bal 32d 150,000.
e Tax deposited with Form 7004 . . . . . . . . . . . . . . . 32e
f Credits: (1) Form 2439 (2) Form 4136 32f
g Refundable credits from Form 3800, line 19c, and Form 8827, line 8c . . . 32g 32h 150,000.
33 Estimated tax penalty (see instructions). Check if Form 2220 is attached . . . . . . . . X 33 3,268.
34 Amount owed. If line 32h is smaller than the total of lines 31 and 33, enter amount owed . . . . . . 34 93,818.
35 Overpayment. If line 32h is larger than the total of lines 31 and 33, enter amount overpaid . . . . . . 35
36 Enter amount from line 35 you want: Credited to 2009 estimated tax Refunded 36
Under penalties of perjury, I declare that I have examined this return, including accompanying schedules and statements, and to the best of my knowledge and belief, it is true,
correct, and complete. Declaration of preparer (other than taxpayer) is based on all information of which preparer has any knowledge.
Sign May the IRS discuss this return
with the preparer shown below
Here (see instructions)? Yes No
Signature of officer Date Title
b Did any individual or estate own directly 20% or more, or own, directly or indirectly, 50% or more of the total voting power of all
classes of the corporation’s stock entitled to vote? . . . . . . . . . . . . . . . . . . . . . . . X
For rules of constructive ownership, see instructions. If “Yes,” complete (i) through (iv).
(ii) Identifying Number (iii) Country of Citizenship (iv) Percentage
(i) Name of Individual or Estate Owned in Voting
(if any) (see instructions)
Stock
a Own directly 20% or more, or own, directly or indirectly, 50% or more of the total voting power of all classes of stock entitled to vote of any
foreign or domestic corporation not included on Form 851, Affiliations Schedule? For rules of constructive ownership, see instructions .
X
If “Yes,” complete (i) through (iv).
(ii) Employer (iii) Country of (iv) Percentage
(i) Name of Corporation Identification Number Owned in Voting
Incorporation
(if any) Stock
b Own directly an interest of 20% or more, or own, directly or indirectly, an interest of 50% or more in any foreign or domestic partnership
(including an entity treated as a partnership) or in the beneficial interest of a trust? For rules of constructive ownership, see instructions .
If “Yes,” complete (i) through (iv).
(ii) Employer (iv) Maximum
(i) Name of Entity Identification Number (iii) Country of Organization Percentage Owned in
(if any) Profit, Loss, or Capital
6 During this tax year, did the corporation pay dividends (other than stock dividends and distributions in exchange for stock) in
excess of the corporation’s current and accumulated earnings and profits? (See sections 301 and 316.) . . . . . . . .
X
If "Yes," file Form 5452, Corporate Report of Nondividend Distributions.
If this is a consolidated return, answer here for the parent corporation and on Form 851 for each subsidiary.
7 At any time during the tax year, did one foreign person own, directly or indirectly, at least 25% of (a) the total voting power of all
classes of the corporation’s stock entitled to vote or (b) the total value of all classes of the corporation’s stock? . . . . . X
For rules of attribution, see section 318. If “Yes,” enter:
(i) Percentage owned and (ii) Owner’s country
(c) The corporation may have to file Form 5472, Information Return of a 25% Foreign-Owned U.S. Corporation or a Foreign
Corporation Engaged in a U.S. Trade or Business. Enter the number of Forms 5472 attached
8 Check this box if the corporation issued publicly offered debt instruments with original issue discount . . . . . .
If checked, the corporation may have to file Form 8281, Information Return for Publicly Offered Original Issue Discount Instruments.
9 Enter the amount of tax-exempt interest received or accrued during the tax year $
10 Enter the number of shareholders at the end of the tax year (if 100 or fewer)
11 If the corporation has an NOL for the tax year and is electing to forego the carryback period, check here . . . . . .
If the corporation is filing a consolidated return, the statement required by Regulations section 1.1502-21(b)(3) must be attached or
the election will not be valid.
12 Enter the available NOL carryover from prior tax years (do not reduce it by any deduction on line 29a.) $
13 Are the corporation’s total receipts (line 1a plus lines 4 through 10 on page 1) for the tax year and its total assets at the end of the
tax year less than $250,000? . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . X
If “Yes,” the corporation is not required to complete Schedules L, M-1, and M-2 on page 5. Instead, enter the total amount of cash
distributions and the book value of property distributions (other than cash) made during the tax year. $
Form 1120 (2008)
1-26 Income Taxation of Corporations
e ACE adjustment.
● If line 4b is zero or more, enter the amount from line 4c
● If line 4b is less than zero, enter the smaller of line 4c or line 4d as a negative amount }
. . . 4e 0.
5 Combine lines 3 and 4e. If zero or less, stop here; the corporation does not owe any AMT . . . . 5 707,500.
6 Alternative tax net operating loss deduction (see instructions) . . . . . . . . . . . . . . 6
7 Alternative minimum taxable income. Subtract line 6 from line 5. If the corporation held a residual
interest in a REMIC, see instructions . . . . . . . . . . . . . . . . . . . . . . 7 707,500.
8 Exemption phase-out (if line 7 is $310,000 or more, skip lines 8a and 8b and enter -0- on line 8c):
a Subtract $150,000 from line 7 (if completing this line for a member of a
controlled group, see instructions). If zero or less, enter -0- . . . . . . . 8a
b Multiply line 8a by 25% (.25) . . . . . . . . . . . . . . . . . . 8b
c Exemption. Subtract line 8b from $40,000 (if completing this line for a member of a controlled group,
see instructions). If zero or less, enter -0- . . . . . . . . . . . . . . . . . . . . 8c 0.
9 Subtract line 8c from line 7. If zero or less, enter -0- . . . . . . . . . . . . . . . . . 9 707,500.
10 If the corporation had qualified timber gain, complete Part II and enter the amount from line 24 here.
Otherwise, multiply line 9 by 20% (.20) . . . . . . . . . . . . . . . . . . . . . 10 141,500.
11 Alternative minimum tax foreign tax credit (AMTFTC) (see instructions) . . . . . . . . . . . 11
12 Tentative minimum tax. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . 12 141,500.
13 Regular tax liability before applying all credits except the foreign tax credit . . . . . . . . . 13 240,550.
14 Alternative minimum tax. Subtract line 13 from line 12. If zero or less, enter -0-. Enter here and on
Form 1120, Schedule J, line 3, or the appropriate line of the corporation’s income tax return . . . 14 0.
For Paperwork Reduction Act Notice, see the instructions. Cat. No. 12955I Form 4626 (2008)
1-28 Income Taxation of Corporations
2 Short-term capital gain from installment sales from Form 6252, line 26 or 37 . . . . . . . . . . 2
3 Short-term gain or (loss) from like-kind exchanges from Form 8824 . . . . . . . . . . . 3
4 Unused capital loss carryover (attach computation) . . . . . . . . . . . . . . . . 4 ( )
5 Net short-term capital gain or (loss). Combine lines 1 through 4 . . . . . . . . . . . . 5
Part II Long-Term Capital Gains and Losses—Assets Held More Than One Year
19 Enter the date of payment or the 15th day of the 3rd month
after the close of the tax year, whichever is earlier (see See Stmt
instructions). (Form 990-PF and Form 990-T filers: Use 5th
month instead of 3rd month.) . . . . . . . . . 19
20 Number of days from due date of installment on line 9 to the
date shown on line 19 . . . . . . . . . . . . 20
37 Add lines 22, 24, 26, 28, 30, 32, 34, and 36 . . . . . 37 $ $ $ $
38 Penalty. Add columns (a) through (d) of line 37. Enter the total here and on Form 1120, line 33;
or the comparable line for other income tax returns . . . . . . . . . . . . . . . . . . . . 38 $ 3,268.
*Use the penalty interest rate for each calendar quarter, which the IRS will determine during the first month in the preceding quarter.
These rates are published quarterly in an IRS News Release and in a revenue ruling in the Internal Revenue Bulletin. To obtain this
information on the Internet, access the IRS website at www.irs.gov. You can also call 1-800-829-4933 to get interest rate
information.
Form 2220 (2008)
Solutions for Tax Return Problems 1-31
Name ID No.
Sam Smith 446-46-4646
1-34 Although the calculations in this problem are relatively simple and straightforward, many students may
overlook the importance of the AMT credit in answering the question regarding the choice of depreciation
methods.
If Paul Schroeder chooses to depreciate the personalty acquired by ABC using MACRS, the corporation
will pay an AMT tax of $11,750 and a total tax of $92,500, and will have an AMT credit carry forward of
$11,750.
The AMT is $11,750 ($92,500 $80,750); the total tax paid is $92,500; and the AMT credit carryforward is
$11,750.
If Paul Schroeder chooses to depreciate the personalty acquired by ABC using AMT ADS, the corporation
will pay an AMT tax of $6,875 ($92,500 $85,625) and a total tax of $92,500, and will have an AMT
credit carryforward of $6,875.
ABC Corporation pays the same total tax either way. So which method of depreciation should be
selected? If MACRS is selected, the AMT credit carryover is $4,875 greater than the credit generated if
AMT ADS is selected ($11,750 $6,875). If this credit can be used in the near future to reduce the regular
tax, this is a real advantage for choosing MACRS. However, if the corporation stays in an AMT situation
indefinitely, the method of depreciation will not matter.
1-34 Income Taxation of Corporations
e ACE adjustment.
● If line 4b is zero or more, enter the amount from line 4c
● If line 4b is less than zero, enter the smaller of line 4c or line 4d as a negative amount }
. . . 4e
5 Combine lines 3 and 4e. If zero or less, stop here; the corporation does not owe any AMT . . . . 5 462,500
6 Alternative tax net operating loss deduction (see instructions) . . . . . . . . . . . . . . 6
7 Alternative minimum taxable income. Subtract line 6 from line 5. If the corporation held a residual
interest in a REMIC, see instructions . . . . . . . . . . . . . . . . . . . . . . 7 462,500
8 Exemption phase-out (if line 7 is $310,000 or more, skip lines 8a and 8b and enter -0- on line 8c):
a Subtract $150,000 from line 7 (if completing this line for a member of a
controlled group, see instructions). If zero or less, enter -0- . . . . . . . 8a
b Multiply line 8a by 25% (.25) . . . . . . . . . . . . . . . . . . 8b
c Exemption. Subtract line 8b from $40,000 (if completing this line for a member of a controlled group,
see instructions). If zero or less, enter -0- . . . . . . . . . . . . . . . . . . . . 8c -0-
9 Subtract line 8c from line 7. If zero or less, enter -0- . . . . . . . . . . . . . . . . . 9 462,500
10 If the corporation had qualified timber gain, complete Part II and enter the amount from line 24 here.
Otherwise, multiply line 9 by 20% (.20) . . . . . . . . . . . . . . . . . . . . . 10 92,500
11 Alternative minimum tax foreign tax credit (AMTFTC) (see instructions) . . . . . . . . . . . 11
12 Tentative minimum tax. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . 12 92,500
13 Regular tax liability before applying all credits except the foreign tax credit . . . . . . . . . 13 80,750
14 Alternative minimum tax. Subtract line 13 from line 12. If zero or less, enter -0-. Enter here and on
Form 1120, Schedule J, line 3, or the appropriate line of the corporation’s income tax return . . . 14 11,750
For Paperwork Reduction Act Notice, see the instructions. Cat. No. 12955I Form 4626 (2008)
Solutions for Tax Return Problems 1-35
e ACE adjustment.
● If line 4b is zero or more, enter the amount from line 4c
● If line 4b is less than zero, enter the smaller of line 4c or line 4d as a negative amount }
. . . 4e
5 Combine lines 3 and 4e. If zero or less, stop here; the corporation does not owe any AMT . . . . 5 462,500
6 Alternative tax net operating loss deduction (see instructions) . . . . . . . . . . . . . . 6 -
7 Alternative minimum taxable income. Subtract line 6 from line 5. If the corporation held a residual
interest in a REMIC, see instructions . . . . . . . . . . . . . . . . . . . . . . 7 462,500
8 Exemption phase-out (if line 7 is $310,000 or more, skip lines 8a and 8b and enter -0- on line 8c):
a Subtract $150,000 from line 7 (if completing this line for a member of a
controlled group, see instructions). If zero or less, enter -0- . . . . . . . 8a
b Multiply line 8a by 25% (.25) . . . . . . . . . . . . . . . . . . 8b
c Exemption. Subtract line 8b from $40,000 (if completing this line for a member of a controlled group,
see instructions). If zero or less, enter -0- . . . . . . . . . . . . . . . . . . . . 8c -0-
9 Subtract line 8c from line 7. If zero or less, enter -0- . . . . . . . . . . . . . . . . . 9 462,500
10 If the corporation had qualified timber gain, complete Part II and enter the amount from line 24 here.
Otherwise, multiply line 9 by 20% (.20) . . . . . . . . . . . . . . . . . . . . . 10 92,500
11 Alternative minimum tax foreign tax credit (AMTFTC) (see instructions) . . . . . . . . . . . 11
12 Tentative minimum tax. Subtract line 11 from line 10 . . . . . . . . . . . . . . . . . 12 92,500
13 Regular tax liability before applying all credits except the foreign tax credit . . . . . . . . . 13 85,625
14 Alternative minimum tax. Subtract line 13 from line 12. If zero or less, enter -0-. Enter here and on
Form 1120, Schedule J, line 3, or the appropriate line of the corporation’s income tax return . . . 14 6,875
For Paperwork Reduction Act Notice, see the instructions. Cat. No. 12955I Form 4626 (2008)