ACC 377 Lecture Notes - Lecture 4: Contract, Gross Income, Payment

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18 May 2018
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Life insurance coverage provided by an employer for a group of employees. Such insurance is renewable
on a year-to-year basis, and typically no cash surrender value is built up. The premiums paid by the
employer on the insurance are not taxed to the employees on coverage of up to $50,000 per person. §
79 and Reg. § 1.79-1(b).
Annuity
A fixed sum of money payable to a person at specified times for a specified period of time or for life. If
the party making the payment (i.e., the obligor) is regularly engaged in this type of business (e.g., an
insurance company), the arrangement is classified as a commercial annuity. A so-called private annuity
involves an obligor that is not regularly engaged in selling annuities (e.g., a charity or family member).
Imputed Interest
For certain long-term sales of property, the IRS can convert some of the gain from the sale into interest
income if the contract does not provide for a minimum rate of interest to be paid by the purchaser. The
seller recognizes less long-term capital gain and more ordinary income (interest income). § 483 and the
related Regulations.
Alimony Recapture
Definition:
The amount of alimony that previously has been included in the gross income of the recipient and
deducted by the payor that now is deducted by the recipient and included in the gross income of the
payor as the result of front-loading. § 71(f).
Alimony and Separate Maintenance Payments
Alimony deductions result from the payment of a legal obligation arising from the termination of a
marital relationship. Payments designated as alimony generally are included in the gross income of the
recipient and are deductible for AGI by the payor.
S Corporation
The designation for a small business corporation. See also Subchapter S.
Partnership
For income tax purposes, a partnership includes a syndicate, group, pool, or joint venture, as well as
ordinary partnerships. In an ordinary partnership, two or more parties combine capital and/or services
to carry on a business for profit as co-owners. § 7701(a)(2).
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