USC LEVENTHAL SCHOOL OF ACCOUNTING
ACCT 551T
TAXATION OF PARTNERSHIPS AND S CORPORATIONS
Summer 2009
Wed 6:00 p.m. – 10:00 p.m.
SYLLABUS
INSTRUCTORS: Terry Krupczak, 213 240-7166, (S corp’s)
Brian Ladin, 805 778-7012, (Partnerships)
Bill Woods 213 977-3689, (Partnerships)
OFFICE HOURS: Wednesday from 5:00 to 6:00
by appointment please
EMERGENCY NUMBERS:
USC Emergencies 740-4321
USC Emergency Information Line 740-9233
USC Information Line 740-2311
KUSC Radio 91.5
REQUIRED TEXT: Internal Revenue Code and Regulations
Willis, Pennell, & Postlewaite
Partnership Taxation
Fifth (Student) Edition
Warren Gorham & Lamont
Eustice & Kuntz
Federal Income Taxation of S Corporations
Warren Gorham & Lamont
(Available on-line)
PREREQUISITES: ACCT 550T or ACCT 560T or LAW 600
Co-requisites: none
COURSE OBJECTIVE: This course is a graduate level study of the federal income taxation of partnerships, S corporations, and limited liability companies. The course examines various tax consequences in the life of the entity, including tax and non-tax aspects involved in choosing the appropriate flow-through entity.
GRADING:
DUE DATE: %
HOMEWORK PROBLEMS See syllabus 10%
MIDTERM EXAM July 1st 30%
CASE STUDIES See syllabus 20%
FINAL EXAMINATION August 5th 30%
CLASS PARTICIPATION 10%
Grades will be determined on a curve. The School of Accounting grading standards (including important dates) is attached and will be observed.
GRADING POLICY:
1. Both examinations will be “open book” (Code, Regs, text, notes, and assigned readings only). Make up examinations will generally not be given, except in the case of a well-documented true emergency. All students must take the final exam as scheduled unless an incomplete contract has been previously approved according to Leventhal School of Accounting rules.
2. The case studies will be evaluated based on content as well as on the effectiveness of your communication. This includes grammar, spelling, organization, and other essentials of effective communication. The case studies are due on June 10th and July 22nd – no exceptions. The topic and specific instructions will be distributed separately.
3. Students are expected to present to the class at least one study problem during the semester, which will generally be assigned a week in advance. The class participation grade will consist of the required attendance and advanced preparation of the assignments.
4. Homework problems are assigned in the syllabus. The homework portion of your grade (10%) will be based on the answers submitted for the designated problems. A 5-point penalty will be imposed for each class session that an assignment is late. The other homework problems will not be collected, but they will be discussed in class and advance preparation of the problems is recommended. This will be part of your participation grade.
5. All graded materials not returned to the student will be retained for one additional semester following the student’s receipt of their grade. Returned paperwork, unclaimed by a student, will be discarded after the date of the final examination.
STUDENT HONOR CODE:
All students are bound by the standards established in the Student Honor Code. Cooperation with other students on homework problems that are not to be turned in for a grade is permitted. Cooperation with other students on the case study or homework problems that will be collected for a grade is not permitted.
STATEMENT FOR STUDENTS WITH DISABILITIES:
Any student requesting academic accommodations based on a disability is required to register with Disability Services and Programs (DSP) each semester. A letter of verification for approved accommodation can be obtained from DSP. Please be sure the letter is delivered to me as early in the semester as possible. DSP is located in STU 301 and is open 8:30 a.m. – 5:00 p.m., Monday through Friday. The phone number for DSP is (213) 740-0776.
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SCHEDULE – ACCT 551T – Summer 2009
Class / Date / Topic / Assignment / Hand In1 / May 27th / Introduction / Definition of Entities / Check-the-Box Regulations/ Formation and Funding of the Partnership / Partnership Tax Year
Pennell: ¶¶ 1.01[1]; 1.02[1] – [7]; 1.03[1] –[2]; 1.06[1], [3], 1.04; 4.02[1] – [6]; 4.03; 9.05[1] – [3]
Code: §§ 7701(a)(1), (2), (3); 761(a) – (c); 706(b); 721; 722; 723; 724
Regs: § 301.7701-1, -2, -3; §§ 1.706-1(b)(1), (2), (3), (7), (8);
1.721-1(a); 1.722-1; 1.723-1
Read:
· Rev. Proc. 2002-22
· Rev. Rul. 75-374
· Rev. Rul. 2004-77
· Rev. Proc. 2002-69
Prepare: Study Problems Class 1
2 / June 3rd / Partnership Taxation / Allocations / Basis
Pennell: ¶¶ 5.01; 5.02; 5.04; 9.01[1], [4], [8], [9], [10][a], [13], [14]; 9.06[1], [2], [3], [6], [7]; 10.01[1], [2], 10.08[1]
Code: §§ 701; 702; 703; 704; 705; 706(a), (c), (d)
Regs: §§ 1.701-1; 1.702-1; 1.703-1; 1.704-1(a), (d); 1.705-1(a); 1.706-1(c)
Prepare: Study Problems Class 2 / Study Problems Class 2
3 / June 10th / Partnership Liabilities / Disguised Sales
Pennell: ¶¶ 4.04[1], [2]; 6.01[2] – [5]; 6.02[1] – [3], [5]; 4.02[7][a] – [g]
Code: §§707(a); 752
Regs: §§ 1.707-3; -4; -5; 1.752-1; -2(a), (b)(1)
Prepare: Study Problems Class 4 / Case study
4 / June 17th / Distributions from Partnerships
Pennell: ¶¶ 13.02 – 13.02[1][a][i], [b]; 13.02[2], [6][a]; 13.03[1] – [3]
Code: §§ 731(a), (b); 732; 733; 735
Regs: §§ 1.731-1; 1.732-1(a), (b), (c); 1.733-1; 1.735-1
Read:
· Rev. Rul. 94-4
· Rev. Rul. 87-120
Prepare: Study Problems Class 4 / Study problems class 4
5 / June 24th / Termination of Partnership
Pennell: ¶¶ 16.01[1], [2], [4], [5], [6], [7], [8]; 16.02[1], [2]
Code: §§ 706(c); 708; 741
Regs: §§ 1.706-1(c); 1.708-1(a), (b); 1.761-1(d)
Read:
· Rev. Rul. 81-38
· Rev. Rul. 87-110
· Rev. Rul. 99-5
· Rev. Rul. 99-6
Prepare: Study Problems Class 5
6 / July 1st / MIDTERM EXAM
7 / July 8th / S Corporations – Eligibility / Tax Year/Election
E&K: ¶¶ 3.01; 3.03[1], [6], [7], [8], skim [9], skim [11], skim [12], [13], [14], [15]; 3.04; 3.07[1], [2], [3][a], [b]; 3.08[1], [2], [3][a], [4]; 3.09[1][b]; 3.10; ¶¶ 4.01; 4.02; skim 4.03; 4.06[2][a], [3]. [4]; 4.07; 4.08; 4.09
Code: §§ 1361; 1362(a), (b), (c), (f), (g)
Regs: §§ 1.1361-1; Prop. Reg. § 1.1361-1(e); § 1.1361-2; 1.1362-1, -6; 1.1361-3, -4(a)(1) & (2)
Read:
· Rev. Rul. 89-55
· Rev. Rul. 92-20
· Rev. Rul. 94-43
· Rev. Proc. 2003-43
· Rev. Proc. 2004-48
· Rev. Proc. 2004-49
· Rev. Proc. 2007-62
· IRS Form 2553 and Instructions
Prepare: Study Problems Class 7
8 / July 15th / Basis / Allocation of Income and Losses
E&K: ¶¶ 7.02[1] through [6]; 9.01; 9.02; 9.03[1][a],[b], [e], [f], [g]; 9.03[2], [3], [4][b], [5]; 9.05[1][a], [b], [c]; 9.05[2][a], [b], [c][i]
Code: §§ 1366; 1367; 1377(a)
Regs: §§ 1.1366-1, -2(a); 1.1367-1,-2; 1.1368-1(g)(2); 1.1377-1
Read:
· Rev. Rul. 64-162
· Rev. Rul. 68-537
· Rev. Rul. 74-44
· Oren v. Commissioner, 357 F.3d 854 (8th Cir. 2004)
Prepare: Study Problems Class 8 / Study Problem 8
9 / July 22nd / S Corporation Distributions
E&K: 8.01[1], [2]; 8.02; 8.03; 8.04; 9.03[4][b]
Code: § 1368
Regs: §1.1368-1, -2, -3
Read: Rev. Rul. 95-14
Prepare: Study Problems Class 12 / Case Study
10 / July 29 / Taxation and Termination of S Corporations
E&K: ¶¶ 7.06[1], [3], [4][a] through [h]; 5.01[1]; 5.02; 5.03[1], [8]; 5.04[1], [2][a], [b], [3]; 5.07[1], [2][b] (see supp); 5.09[1] through [5]; 8.05
Code: §§ 1362(d(3); 1363; 1371; 1374; 1375; 1362(d), (e), (f); 1377(b); 1371(e); 1366(d)(3)
Regs: §§ 1.1374-1, -2, -3, -4(a), (b); 1.1362-2, -3, -4, -5, review –6; 1.1377-2
Read: Review Rev. Proc. 2003-43
Prepare: Study Problems Class 10 / Study problem 10
11 / August 5th / FINAL EXAM 6 p.m. – 9 p.m.
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