Cumulative Assignments for Corporate Taxation

Professor Daicoff

Spring, 2000

For Week 1: Friday, January 14, 2000

Texts:

  1. Lind, Schwarz, Lathrope, and Rosenberg, Fundamentals of Corporate Taxation, Fourth Edition (Foundation Press, 1997).
  2. Commerce Clearing House, Federal Income Tax Code and Regulations, Selected Sections, 1999-2000 Edition. You may have elected not to purchase the Selected Sections but instead elected to buy the multi-volume sets of the Code and Regs., which is fine.

The Bittker & Eustice book, Federal Income Taxation of Corporations and Shareholders (and its supplement), is a hornbook which is recommended but is not a required text for this course. You may read the chapters in this hornbook which correspond to the topics being covered in class each week.

Assignment for Week 1:

Lind text: Read pages 1-42.

Code and Regs.: Read Code and Regulation sections as assigned by the Lind text (for example, see page 10 of the Lind text assigning Code Sections 11, 63(a), etc. You are responsible for reading any Code or Regulation sections so assigned by the Lind text.)

In addition, please read Regulation Sections 301.7701-1, -2, -3, and -4. This encompasses the "Check-The-Box" regulations, which are no longer proposed as the Lind text indicates at pages 31-33, but became effective January, 1997.

For Week 2: January 21, 2000

Read: Text pages 43-80 and skim Supplement pages 5-18.

Code and Regs: As assigned by the Text and modified as follows: §§351 (skim (e) & (f)); 362(a); 358(a); 1032(a); 1223(1) flush language only & (2); 368(c); 1245(b)(3); 357; 358(d). [Optional: Regs. §1.351-1(a)(1); Prop. Regs. §1.453-1(f)(3)(ii) and -f(1)(iii).] Regs. §§1.357-1 and -2; 1.358-3.

Do: Problems on pages 46; 53 (skip part (e) of 2.); and 63 (part (a) only; skip (b)).

NOTE: B&E is particularly useful in the area of Code Section 351; you may wish to read parts of it in connection with this assignment.

 

For Week 3:

Read: Text pages 80-101 (omit Fink case at pages 92-98).

Code and Regs: as assigned by the Text.

Do: Problems on page 80 (skip parts (b), (c), and (d) of 2.);

Problem on page 90 (skip parts (d) and (f)); and

Problem on page 100 (do part (c) only).

Assignment for Week 4:

Ch. 3. The Capital Structure of a Corporation

A. Introduction

B. Debt vs. Equity

C. The §385 Saga

D. Character of Loss on Corporate Investment

Ch. 4. Nonliquidating Distributions

A. Dividends

B. E+P

Read: Text pages 102-104 and pages 108-140 and Code and Regulations as assigned by the Text.

Do: Problems on p. 123 (skip part 2.) and Problem on p. 140 (use text p. 138-140 to work this problem).

Assignment for Week 5:

Read: Text pages 141-157 carefully, skim pages 157-177, read pages 177-182 carefully.

Do: Problems p. 144 and 148 (omit part (e)).

Assignment for Week 6: Friday, February 18, 2000

Read text pages 182-213 and Code and Regs. Sections as assigned by the text. Do problems on pages 182, 186, and 202.

Assignment for Week 7: Friday, February 25, 2000

Read text pages 214-229, skim ½ way through 234 – ½ way through 245 (on buy-sell agreements), read 264-268, and read 276-278 and Code and Regs. Sections as assigned by the text. Do problems on pages 219-220, 223-224 (skip part (h)), and 227. Read supplement page 22.

Assignment for Week 8: Friday, March 3, 2000

Read text pages 279-309 and Code and Regs. Sections as assigned by the text. Do problems on pages 276 (do 2. Only), 289-90 (do 1. Only), and 309-10 (do 1(a)-(e) and skip (f)-(h) and 2.).

Assignment for Week 9 – March 10:

Complete Liquidations

Read Text pages 311-342 and Code and Regs. as assigned by the Text except skip §346(a) and §453(h)(1)(A) - (B).

Do Problems p. 315 (1(a), (b), and (e) only); 328-29 (all); and 340 (all but 1(a) — do as many of the remaining problems as you can — I realize they are quite lengthy. I plan to assign 1(a) as a Review Question at the end of the semester.)

For Week 10:

Finish Ch. 6 on Complete Liquidations

Read text p. 320 – 341 and Code and Regs. as assigned by the text. Do Problems on p. 329 (all) and on 340 (at least all of 1.).

Begin the following (we are not likely to finish through p. 368 before spring break, which is March 18-26):

Ch. 8 Taxable Corporate Acquisitions

Read text p. 342 - 368, supplement p. 23, and Code and Regs. as assigned by the text.

Do Problems p. 364 1.(a), (b), (d), (e), (h) and skip 1 c., f., g., i., j., and 2.

Week 11: March 31 – Project #1 Due. Read text pages 405-440 and all applicable Supplement pages. No problems are assigned. We will probably work on Project #3 in class on this date.

Week 12: April 7 – Read text pages 440-497 and all applicable Supplement pages but omit 475-486. No problems are assigned.

 

Week 13: April 14 – Read text pages 511-513, 533, 542-548, 549-557, 558-563, 611-614, 626, 629, 632-633, 739-744 and all applicable Supplement pages and Code Sections assigned by the text but no Regs. No problems are assigned.

Week 14: April 21 – Do the Review Questions. Project #2 Due.

Optional Review Session - time and date to be determined.

 

Exam: Saturday, May 6, 2000, 9:00 a.m. – noon.