過去問 Property Taxation ３

An office building owned by Bob Elin was condemned by the state on January 2, Year 0. Bob received the condemnation award on March 1, Year 1. In order to qualify for nonrecognition of gain on this involuntary conversion, what is the last date for Bob to acquire qualified replacement property?

a.               August 1, Year 2

b.               January 2, Year 3

c.                March 1, Year 4

d.               December 31, Year 4

8036

Solution　d

聞かれてるのは AGI ではなく、Net Earnings from Self-employment なので、350,000から引くのは35,000、28,000、5,250の Business Expenses まで。

Sands purchased 100 shares of Eastern Corp. stock for $18,000 on April 1 of the prior year. On February 1 of the current year, Sands sold 50 shares of Eastern for $7,000. Fifteen days later, Sands purchased 25 shares of Eastern for $3,750. What is the amount of Sand's recognized gain or loss?

a.               $ 0

b.               $ 500

c.                $ 1,000

d.               $ 2,000

8880

Solution　c

Nonaccountable Plan の場合、Gross Income に入れる。

（ Accountable Plan なら非課税。）

Mileage of ～は、Misc. Itemized Deductions above 2% of your AGI。

Jackson, a single individual, inherited Bean Corp. common stock from Jackson's parents. Bean is a qualified small business corporation under Code sec. 1244. The stock cost Jackson's parents $20,000 and had a fair market value of $25,000 at the parents' date of death. During the year, Bean declared bankruptcy and Jackson was informed that the stock was worthless. What amount may Jackson deduct as an ordinary loss in the current year?

a.               $ 0

b.               $ 3,000

c.                $ 20,000

d.               $ 25,000

7081

Solution　a

親が買った株を相続したから、Loss は取れない。

Long-term Capital Loss として計上はできる。

（ Basis はFMV の25,000）

自分で買ったものであれば、Ordinary Loss として計上できる。

Summer, a single individual, had a net operating loss of $20,000 three years ago. A Code Section 1244 stock loss made up three-fourths of that loss. Summer had no taxable income from that year until the current year. In the current year, Summer has gross income of $80,000 and sustains another loss of $50,000 on Code Section 1244 stock. Assuming that Summer can carry the entire $20,000 net operating loss to the current year, what is the amount and character of the Code Section 1244 loss that Summer can deduct for the current year?

a.               $35,000 ordinary loss

b.               $35,000 capital loss

c.                $50,000 ordinary loss

d.               $50,000 capital loss

90222

Solution　c

Single Taxpayer の場合、Section 1244 の Loss は、Up to 50,000 （夫婦なら100,000）まで Ordinary Loss として取れる。

For federal estate taxation, the alternate valuation date

a.               If elected on the first return filed for the estate, may be revoked in an amended return provided that the first return was filed on time

b.               Is required to be used if the fair market value of the estate’s assets had increased since the decedent’s date of death

c.                Must be used for valuation of the estate’s liabilities if such date is used for valuation of the estate’s assets

d.               Can be elected only if its use decreases both the value of the gross estate and the estate tax liability

1731

Solution　d

払う税金を少なくできるように AVD の設定がある。

Income in respect of a cash basis decedent

a.               Covers income earned before the taxpayer’s death but not collected until after death

b.               Receives a stepped-up basis in the decedent’s estate

c.                Must be included in the decedent’s final income tax return

d.               Cannot receive capital gain treatment

1709

Solution　a

IRD は、死んだ後に振り込まれる給与やボーナス。

Under which of the following circumstances is trust property with an independent trustee includible in the grantor's gross estate?

a.               The trust is revocable.

b.               The trust is established for a minor.

c.                The trustee has the power to distribute trust income.

d.               The income beneficiary disclaims the property, which then passes to the remainderman, the grantor’s friend.

8871

Solution　a

死んだ人が生前に Trust を Setup して、Revoke できる権利を維持していた場合、Gross Estate に入れなければいけない。

Inrevocable なら相続。

Alan Maade, a US citizen, died on March 1, leaving an adjusted gross estate with a fair market value of $1,600,000 at the date of death. Under the terms of Alan's will, $475,000 was bequeathed outright to his widow, free of all estate and inheritance taxes. The remainder of Alan's estate was left to his mother. Alan made no taxable gifts during his lifetime. In computing the taxable estate, the executor of Alan's estate should claim a marital deduction of

a.               $ 250,000

b.               $ 475,000

c.                $ 600,000

d.               $1,125,000

1746

Solution　　b

聞かれてるのは Marital Deduction。

During 2014, Blake transferred a corporate bond with a face amount and fair market value of $20,000 to a trust for the benefit of her 16-year old child. Annual interest on this bond is $2,000, which is to be accumulated in the trust and distributed to the child on reaching the age of 21. The bond is then to be distributed to the donor or her successor-in-interest in liquidation of the trust. Present value of the total interest to be received by the child is $8,710. The amount of the gift that is excludable form taxable gifts is

a.               $28,000

b.               $14,000

c.                $ 8,710

d.               $ 0

2474

Solution　d

Gift of Future Interest は、Nothing gets excluded。

Don and Linda Grant, US citizens, were married for the entire 2014 calendar year. In 2014, Don gave a $60,000 cash gift to his sister. The Grants made no other gifts in 2014. They each signed a timely election to treat the $60,000 gift as one made by each spouse. Disregarding the unified credit and estate tax consequences, what amount of the 2014 gift is taxable to the Grants for gift tax purposes?

a.               $0

b.               $32,000

c.                $46,000

d.               $60,000

7856

Solution　b

夫婦だから14,000 x 2 を Exclude できる。

Donation per year, per donee。

海外格安航空券を探すなら　スカイチケット！