A Memo on IRS Ruling on Capital Expenditure

$19.95

Add to cart
Essay #: 063224
Total text length is 6,730 characters (approximately 4.6 pages).

Excerpts from the Paper

The beginning:
A Memo on IRS Ruling on Capital Expenditure
To:Robin, Inc.
From:(Student Name)
Subject:Five Million dollar judgment
The purpose of this Memo is to determine if Robin, Inc. has any options regarding the IRS determination that the five million dollar judgment against Sparrow must be classified as a capital expenditure. The tax code and the record of appeals provide for exemptions that Robin Inc. may consider
Facts
When Robin purchased Sparrow, Robin Inc., assumed responsibilities for both the assets and liabilities of Sparrow. A jury found that Sparrow was guilty of patent infringement and fined the company five million dollars. Robin Inc. has paid that judgment. Robin Inc. deducted the payment as a business expense. The IRS has reclassified...
The end:
.....rming, or if the company is considered small. If both these criteria are met (1) the cost of the appeal is less than the cost of paying taxes, and (2) the company does qualify under one or more exemption, then it makes sense to consider appealing this decision.
References
www.irs.gov
http://www.taxalmanac.org/index.php/Sec._263
http://www.law.cornell.edu/uscode/uscode26/usc_sec_26_00000263---A000-.html
http://search.irs.gov/web/query.html?col=allirs&charset=utf-8&qp=&qs=-Wct%3A%22Internal+Revenue+Manual%22&qc=&qm=0&rf=0&oq=&qt=263+corporate&search.x=20&search.y=4
Robinson Knife Manufacturing Company, Inc. and Subsidiary v. Commissioner of Internal Revenue (Docket No. 09-1496-a; Decided March 19, 2010)