The Eggers Corporation filed an amended Form 1120, claiming an additional $400,000 deduction for payments to a

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The Eggers Corporation filed an amended Form 1120, claiming an additional $400,000 deduction for payments to a contractor for a prior tax year. The amended return was based on the entity’s interpretation of a Regulation that defined deductible advance payment expenditures. The nature of Eggers’s activity with the contractor did not exactly fit the language of the Regulation. Nevertheless, because so much tax was at stake, Eggers’s tax department decided to broaden its interpretation and claim the deduction.

Eggers’s tax department estimated that there was only a 15% chance that Eggers’s interpretation would stand up to a Tax Court review. Eggers is subject to a marginal Federal tax rate of 35%.

a. What is the amount of tax penalty that Eggers is risking by taking this position?

b. What would be the result if there was a 45% chance that Eggers’s interpretation of the Regulation was correct?

c. Construct an Excel formula that would generate the correct answer for parts (a) and (b).

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South Western Federal Taxation 2018 Corporations Partnerships Estates And Trusts

ISBN: 1389

41st Edition

Authors: William H. Hoffman, William A. Raabe, James C. Young, Annette Nellen, David M. Maloney

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