Second Chance for Depreciation - Analyzing Tax Planning Opportunities After Asset Disposition

Teaching Objectives

While there is a wealth of technical material incorporated in the Case, the primary learning objectives are to develop an understanding of the interrelationship of the Code, the Courts, and the Internal Revenue Service in the interpretation and development of the tax law.  The practice sets require that the students learn to find, interpret and apply the Code.  The practice sets lead the students to committee reports, professional literature, and historical notes on the Code.  The students develop an understanding of the role of the Internal Revenue Service in the interpretation of the tax law.  To complete the practice sets they must read and interpret Regulations, Revenue Rulings, Revenue Procedures, and other interpretive and legislative sources of administrative authority.  The students will learn the role and relationship of the Tax Court to the other Courts, the standards of review of the Courts of Appeals, the role of the Supreme Court, the importance of the various court opinions in the interpretation of the law and how conflicts between the courts affect the relevance of those decisions.  The students learn to document the relevance and relative weight of primary sources of tax law and to communicate the results of their research to a client or supervisor.  Importantly, the students learn to read and apply the ethical standards and rules of responsibility with an emphasis on tax return positions, due diligence and conflicts of interest.  At the end of the closed fact case the students learn how to comply with the filing requirements necessary to put into effect the conclusions of their research project.  The development of technical knowledge, analytical and spreadsheet skills necessary to complete a planning engagement for a prospective investment are developed as an integral part of these practice sets.