ACC 6073-Corporate Taxation-Fall 2011
Student Presentations:
The goal of this exercise is to enhance learning of specific topics in the field of corporate taxation.   Pairs of students will study and present a court case related to one of the topics.  Teams will 1) prepare a paper (3-4 pages), 2) present the case in class, and 3) lead a brief discussion about their case.  The presentation/discussion should last about 12-15 minutes.    

Although each of the listed cases had a “winning” and a “losing” side, these cases would not have gotten to court unless each side has a credible argument to support its position.  Because the arguments made by both sides can deepen our understanding of the issues, I would like each student to present the case from the perspective of one of the parties by choosing a “side,” and becoming an “advocate” for that party’s position.     

The presentation should include 1) A statement of the case’s relevant facts, 2) A statement of the relevant issue(s), 3) A statement of the case’s holding(s), 4) A statement by each student of the argument(s) for their side and why they believe their side should have prevailed, using the arguments made in the case, (and/or arguments of their own) to support their position.  5) A brief discussion led by presenters in which they solicit comments from the class.   Presenters, as leaders of the discussion, should prepare at least two "discussion starter" questions move the discussion forward.  Presenters may also field questions from the instructor.

The jointly prepared paper should include a statement of the facts, issue(s) and holding of the case, and a summary of the argument(s) made by the government and by the taxpayer (each student writes this part for the side he/she chooses). The paper is due on the students’ presentation date.

Those not presenting are to 1) read each case in advance, 2) be ready to participate in the discussion, and 3) to state and support their agreement or disagreement with the holding.

Topics/Cases:						 Date		Presenters
I.  Corporate Organization/Section 351			
American Bantam Car-- 11 TC 397 (1948)			9/29	Alex Carter, Adam Scott
Lessinger v. CIR—872 F2d 519 (CA 2 1989)		9/29	Matt Hughes, Jon Choi

II. Corporate Capital Structure: Debt vs. Equity
Paulsen v. CIR-- 469 US 131 (1985)	 		10/6	Karla Larios, Justin McCelvey
Peracchi v. CIR 143 F3rd 487 (CA 9 1998)		10/6	Alexia Balli, Justin Bexley
Fin Hay Realty v US-398 F2d 694 (1968)			10/13	Patrick Stephens, Justin Avants

III. Dividends and other Non-Liquidating Distribution
Caruth Corp v US-864 F 2d 644 (1989) 			10/27	Vanessa and Jordan
Litton Industries- 89 TC 1086 (1987) acq	        		10/27	Emily Christen, Laura Collie
Alterman Foods Inc. v US-- 611 F 2d 866 (1979) 		11/3	Jaclyn Good, Jonathan Wetzien

IV. Stock Redemptions
US v Davis 397 US 301--(1970)				11/10    Briana Ramirez, Jackie Benavidez
Commissioner v. Fink   483 US 89 (1987)			11/10	Steven Guerra, Raymond Hupp
Zenz v. Quinlivan 213 F 2d 914--(1954)			11/17	Kristie Kvernen, Ya Huang

V.  Reorganizations
West Coast Marketing Corp. 46 TC 32 (1966)		11/17	Santiago Coindreau

VI. Complete Liquidations 
Arrowsmith v CIR 344 US 6 (1952)			12/1	Sheldon and Victoria Lahti