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Essay Instructions: ?Mr. Pink owns all the shares of XYZ Corporation a subchapter C corp. and leases property to XYZ Corporation. XYZ Corporation has Earnings and Profits of one million dollars for the taxable year 2014 before paying Mr. Pink a salary. XYZ Corporation has cash of $1.2 million and disposable appreciated property with a FMV of $500,000 and a basis of $200,000.?

? What is the best way to split income between XYZ Corporation and Mr. Pink to minimize double tax liability? Consider what may be ?Constructive Distributions?.
? What doctrines apply?

? How does the reduced tax rate on qualified dividends affect tax planning?

? The prototypical transaction giving rise to constructive dividends sometimes involve blatant attempts by taxpayers to milk their corporation while avoiding double tax and involve a direct payment or receipt of an economic benefit by the shareholder, and resolution of the issue requires an evaluation of all the facts and circumstances, applying broad standards such as ?reasonable compensation? ?shareholder benefit vs. corporate benefit? and ?intent?.


? How much salary should XYZ corporation pay Mr. Pink?

? What else can reasonably be paid as a salary to Mr. Pink?
? What other payments can be made to Mr. Pink? See Menard, Inc. v. Commissioner, 560 F.3d 620 (7th Cir. 2009), Hood v. Commissioner, 115 T.C. 172 (2000), Nicholls, North, Buse Co., v. Commissioner 56 T.C. 1225 (1971).
Assume any distributions to the Shareholder are non-liquidating distributions.
? Is XYZ Corporation entitled to non-recognition of gain if it distributes appreciated property to a shareholder instead of selling it? Read General Utilities & Operating Co. v. Helvering 296 U.S. 200, 56 S. Ct. 185 (1935). Also read IRS code section 311(a) (2) and IRC section 311(b). See also Treasury Regulations Sec. 1.301-1(j).

? What are the effect of non-liquidating distributions on E&P? See IRC sections 312(a) (3) and 312(b) (2).


? Are there any Holding Company issues if the XYZ Corporation does not distribute E&P?

Essay Instructions: Mr.Issler, your patient, recently moved in with his daughter-in-law after his wife passed away two months ago. the daughter-in-law is no longer married to amr. Issler's son, but she is at this emergency room visit with Mr. Issler and states that she wants to help take care of Mr.Issler. She tells you that when Mr. Issler got off the airplane after a two and a half hour flight, he was pale and diaphoretic. She took him to the emergency room at the hospital. he was seen by a cardiologist and has a follow-up appointment next week for an echo cardiogram. the patient tells you he has congestive heart failure (CHF) and a history of deep vein thrombosis (DVT). the cardiologist told him to seek out a primary care provider and have his thyroid checked. the patient tells you he does not know if he has hyper or hypo thyroidism, but he has been taking thyroid medication for years. Mr Issler has a large bag of medications with him, including synthroid, lasic, coumadin, and metoprolol. Mr. Isslee is very pale.

His vital signs are as follows: pulse (58), b/p (176/84), respirations (22), pulse oximetry (88). he is 72 inches tall and weighs 147 pounds. his lab results are as follows: hematocrit (29.6%), henoglobin (10.4) BUN (29), creatinine (2.0), and IND (2.5)


write a 700 to 1200 word paper as an introduction ro your plan of care with the following elements.

Analysis of the congruence of concepts and theoretical statements in your nursing plan of care

determination of the current influences of research utilization in practice.

At least two peer reviewed articles

Essay Instructions: Mr.Billups Paper

Read the information which follows concerning the conduct of Mr.Patrick Billups, a high school history teacher and write a paper in IRAC (Issue, rule, analysis & conclusion)format in which you discuss:

1. Whether there has been a possible violation of the student?s Constitutional rights. Be specific as to the actual provisions of the Constitution which may have been violated.

2. Whether there has been any tort offenses committed and if so define and list

3. Against whom the student/parents can file an action in order to achieve a deep pockets recovery.

Mr.Billups Paper

Read the information which follows concerning the conduct of Mr.Patrick Billups, a high school history teacher and write a paper in IRAC format in which you discuss:

1. Whether there has been a possible violation of the student?s Constitutional rights. Be specific as to the actual provisions of the Constitution which may have been violated.

2. Whether there has been any tort offenses committed and if so define and list

3. Against whom the student/parents can file an action in order to achieve a deep pockets recovery.



Mr. Patrick Billups, 9th Grade History

Profile:

Mr. Billups has always enjoyed American history. As a child, he
liked to visit museum and wax works that recreated historical
events, and he now participates in re-enactments of various
battles of the American Revolutionary and Civil Wars.

Mr. Billups wants his students to like history the same way he likes
It. So every event in history, is in some way dramatized in his
classroom. His students enjoy coming to class, and end of unit
evaluations demonstrate that his students are learning. Students
often research various people in history and role-play their
contributions to the developing country. When Mr. Billups taught
the Civil War, ten students in each class were treated as slaves in
the way they would have been treated in history. To illustrate
internment camps during World War II, Mr Billups built a wire cage
in his classroom and required that several students report to him
first thing in the morning and stand in the cage for an entire day.
Of course, this meant that the students missed all of their other
classes for that day.

Communciations:

Notes to and from parents to Mr Billups:

Dear Mr. Billups,

My daughter Li has hardly eaten anything for the past 2 days, and
when I speak to her, she has tears in her eyes. She said that
something happened in your class, but was either too frightened
or too embarrassed to say. I would like Li to understand American
history so that she can be proud of her new country. Will you tell me
what happened in class?

Respectfully,
Li?s father
????????????????????????????_____________________________________

To the parent of Li:

Nothing happened in class. We are studying World War II and the
reaction of Americans to the Japanese attack on Pearl Harbor.
To help my students understand this, I put all of my foreign born
students in a cage for the day. Then we talked about the feelings
on both sides. I like to help my students relive history this way.

Mr Billups

___________________________________

Dear Mr. Billups

We are a proud, honorable family. You have dishonored my
Daughter. Now I understand why she would not speak of this.

I will talk to the school principal about this. I will ask that Li be
placed in a history class with a more sensitive teacher.

Li?s father

Essay Instructions: Mr. Byrne can't understand why scolding his seventh-grade students for disruptive classroom behaviors makes them more unruly. Explain Mr. Byrne's predicament in terms of operant conditioning principles. Show how he could use operant conditioning techniques to (a) reduce disruptive behaviors and (b) increase cooperative behaviors.