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Articles 1 - 24 of 24
Full-Text Articles in Entire DC Network
Crown V. Commissioner: Gift Taxation And Interest-Free Loans Among Family Members
Crown V. Commissioner: Gift Taxation And Interest-Free Loans Among Family Members
William & Mary Law Review
No abstract provided.
Penalizing Bribery Of Foreign Officials Through The Tax Laws: A Case For Repealing Section 162 (C)(1), Christopher Alan Lewis
Penalizing Bribery Of Foreign Officials Through The Tax Laws: A Case For Repealing Section 162 (C)(1), Christopher Alan Lewis
University of Michigan Journal of Law Reform
Most commentary on these congressional attempts to use tax laws to control the ethics of overseas enterprises has centered either on the effectiveness of these provisions or on the burdens and difficulties involved with their implementation. This article, while discussing these issues, is concerned primarily with the conceptual justifications and the direct economic effects of these tax provisions. The article contends that section 162(c)(1) and the pertinent provisions of the Tax Reform Act of 1976 are disguised penalties which often operate arbitrarily and unfairly and concludes that they should be repealed in favor of more equitable and effective deterrents.
Tax Superiority In Bankruptcy—A Study Of Business Bankruptcy Distributions In The Southern And Western Districts Of New York, Peter D. Wolfson
Tax Superiority In Bankruptcy—A Study Of Business Bankruptcy Distributions In The Southern And Western Districts Of New York, Peter D. Wolfson
Buffalo Law Review
No abstract provided.
Current Problems Facing The Executor Taking The Section 2053 Estate Tax Deduction, Jay D. Christiansen
Current Problems Facing The Executor Taking The Section 2053 Estate Tax Deduction, Jay D. Christiansen
Vanderbilt Law Review
Section 2053 of the Internal Revenue Code allows the executor to deduct from the gross estate amounts attributable to expenses, indebtedness, and taxes. This Note will examine problems currently confronting an executor who is attempting to utilize the 2053 deduction. The first problem examined in this Note is the conflict in the federal courts of appeals regarding the deductibility of expenses incurred as a result of a sale of decedent's property. The statute,cases, and regulations in this area will be examined, and a suggested approach for the executor encountering this problem will be provided. The second problem considered is the …
Carter's Projected "Zero-Based" Review Of The Internal Revenue Code: Is Our Tax Code To Be "Born Again"?, L. Hart Wright
Carter's Projected "Zero-Based" Review Of The Internal Revenue Code: Is Our Tax Code To Be "Born Again"?, L. Hart Wright
Michigan Law Review
The evolution of today's Internal Revenue Code, which began with the mere embryo that Congress created in 1913, has absorbed over the ensuing sixty-four years more creative energy on the part of more co-authors than any other law in history. Despite this unstinted expenditure of "blood, sweat, and tears," the resulting document--were it possessed of human senses--would recognize that, for a foreseeable period, its life will be anything but serene. The plight in which it would find itself could even be compared to that early morning scene observed one hundred years ago by General Custer, when hostile forces were massed …
Taxation Of Professional Sports Teams After 1976: A Whole New Ballgame, Howard Zaritsky
Taxation Of Professional Sports Teams After 1976: A Whole New Ballgame, Howard Zaritsky
William & Mary Law Review
No abstract provided.
Domestic International Sales Corporations, George Carey
Domestic International Sales Corporations, George Carey
North Carolina Central Law Review
No abstract provided.
Survey Of Developments In West Virginia Law: 1976
Survey Of Developments In West Virginia Law: 1976
West Virginia Law Review
No abstract provided.
Carryover Basis Rules For Inherited Property, Robert S. Hightower
Carryover Basis Rules For Inherited Property, Robert S. Hightower
Florida State University Law Review
No abstract provided.
Recent Cases, Sara P. Walsh, Don B. Cannada, Frances L. Adams, William T. Luedke, Iv
Recent Cases, Sara P. Walsh, Don B. Cannada, Frances L. Adams, William T. Luedke, Iv
Vanderbilt Law Review
Civil Procedure - Appellate Jurisdiction - Orders Denying Disqualification of Counsel on Ethical Grounds Are Not Final Decisions Subject to Immediate Review Under 28 U.S.C. § 1291
Sara Porter Walsh
Petitioner,' an applicant for a Federal Communications Commission (FCC) broadcasting license, sought interlocutory review of a Commission order' denying a motion to disqualify the law firm that had represented competitor RKO for thirty years. Petitioner alleged that participation by the firm, which included an attorney who was chairman of the FCC while RKO's application was under consideration, constituted a violation of Canons Five and Nine' of the ABA Code of …
Taxpayer Rights In Noncustodial Irs Investigations After Beckwith V. United States, Curtis L. Christensen
Taxpayer Rights In Noncustodial Irs Investigations After Beckwith V. United States, Curtis L. Christensen
University of Michigan Journal of Law Reform
The recent Supreme Court decision in Beckwith v. United States, holding that Miranda does not extend to noncustodial tax investigations, has important implications with respect to the News Release doctrine and the involuntary consent grounds considered in motions to suppress evidence. This article will examine Beckwith and its potential significance with respect to these other doctrines, discussing the factors which the IRS and the courts should consider in order to assure fair treatment of taxpayers during investigations.
Recent Decisions, Steven A. O'Rourke, Henry C. Wood, Jr., Christopher Ryan, Phyllis K. Fong, Clifford D. Harmon
Recent Decisions, Steven A. O'Rourke, Henry C. Wood, Jr., Christopher Ryan, Phyllis K. Fong, Clifford D. Harmon
Vanderbilt Journal of Transnational Law
Admiralty--Workmen's Compensation--Longshoremen's and Harbor Workers' Compensation Act covers Waterfront Injuries to Cargo Handlers Who sometimes work Offshore or Who unpack Containers
Steven A. O'Rourke
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European Communities--Restrictive Practices--Abuse of Dominant Position--Discriminatory or Unfair Pricing Policies among EEC Customers by a Corporation in a Dominant Market Position Infringes Article 86 of the EEC Treaty
Henry Clay Wood, Jr.
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Federal Jurisdiction--State Regulation of Interstate Commerce--Federal Courts have Jurisdiction to Enjoin State Officials from Enforcing State Laws Regulating Interstate Tanker Trade where Congress intended that Federal Regulations Pre-empt the Area
Christopher Ryan
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Securities Regulation--Jurisdiction--Allegations that an International Securities Transaction involving Stock …
A Larson-Zuckman Checklist For Partnership Tax Classification Of Ulpa Real Estate Shelters, J. Durwood Felton Iii
A Larson-Zuckman Checklist For Partnership Tax Classification Of Ulpa Real Estate Shelters, J. Durwood Felton Iii
University of Richmond Law Review
Real estate developments necessarily require large amounts of capital, and are usually dependent on financing from sources other than the venture group assembled to construct and operate a proposed project. Theoretically, such ventures may be undertaken in many forms, corporate and otherwise, and the available financing vehicles may include debt instruments, equity shares and innumerable combinations thereof. In reality, however, business and legal considerations often dictate organization and operation of such ventures within more narrowly defined limits.
Foreign Accumulation Trusts And The Tax Reform Act Of 1976, David H. Simmons
Foreign Accumulation Trusts And The Tax Reform Act Of 1976, David H. Simmons
Vanderbilt Journal of Transnational Law
If the foreign trust is not a grantor trust under the Grantor Trust Provisions (sections 671-679), then the new Act creates several new disparities in the tax treatment between it and a corresponding domestic accumulation trust. Domestic accumulation trusts are no longer subjected to a capital gains throw back, while capital gains of foreign trusts are included in DNI, subject to throw back, and then taxed as ordinary income to the beneficiary because of the abolition of the character rules upon accumulation distribution. Foreign trusts are subjected to throw back of accumulation distributions even though the accumulation was during the …
Recent Decisions, William W. Allen, Alexander A. Hassani, Peter A. Schuller
Recent Decisions, William W. Allen, Alexander A. Hassani, Peter A. Schuller
Vanderbilt Journal of Transnational Law
INCOME TAX--LIQUIDATION OF FOREIGN CORPORATIONS--SHAREHOLDERS IN A LIQUIDATING FOREIGN CORPORATION MUST INCLUDE IN THE CORPORATION'S EARNINGS AND PROFITS ACCOUNT THE AMOUNT OF RECAPTURED EXCESS DEPRECIATION REALIZED UPON THE SALE OF ITS ASSETS
William W. Allen
CUSTOMS DUTIES--ANTIDUMPING ACT OF 1921--THE SECRETARY OF THE TREASURY HAS No AUTHORITY TO TERMINATE A WITH-HOLDING OF APPRAISEMENT PRIOR TO THE PUBLICATION OF A DUMPING FINDING BASED ON A LIKELIHOOD OF INJURY DETERMINATION BY THE INTERNATIONAL TRADE COMMISSION
Alexander A. Hassani
INTERNATIONAL BANKING--BANKRUPTCY-FOREIGN BANKS NEITHER REGULATED BY NOR LICENSED To Do BUSINESS IN THE UNITED STATES MAY FILE FOR VOLUNTARY BANKRUPTCY UNDER THE NATIONAL BANKRUPTCY …
Books Received, Journal Staff
Books Received, Journal Staff
Vanderbilt Journal of Transnational Law
A Practical Guide to U.S. Taxation of Overseas Americans
By Thomas E. Johnson
London: Raftwain Ltd., 1977. Pp. 311. $25.00.
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The Impact of International Organizations on Legal and Institutional Changes in the Developing Countries
New York: International Legal Center, 1977. Pp. 275.
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U.S. Customs Tariffs and Trade
By Eugene T. Rossides
Washington, D.C.: The Bureau of National Affairs, Inc., 1977. Pp. 826. $45.00.
The Tax Reform Act Of 1976, Section 1023: Tax Reform Gone Awry?
The Tax Reform Act Of 1976, Section 1023: Tax Reform Gone Awry?
Maryland Law Review
No abstract provided.
The Taxation Of Distributions From Qualified Employee Benefit Plans, Louis A. Mezzullo
The Taxation Of Distributions From Qualified Employee Benefit Plans, Louis A. Mezzullo
University of Richmond Law Review
One of the most confusing aspects of employee benefit plans is the federal tax treatment of distributions to the participants of these plans and to the beneficiaries of deceased participants. The issues frequently involve not only income taxation, but estate and gift taxation as well. While the average practitioner may never be called upon to draft a pension or profit-sharing plan, he may be asked by his client about the consequences of the various alternative methods
of receiving a benefit from such a plan. Many employee benefit plans, particularly profit-sharing plans, offer a participant upon his retirement from the plan …
Property Taxation In Virginia, Gordon M. Cooley, Burton F. Dodd, Norman T. Fowlkes, Julia Krebs-Markrich, Ronald E. Kuykendall
Property Taxation In Virginia, Gordon M. Cooley, Burton F. Dodd, Norman T. Fowlkes, Julia Krebs-Markrich, Ronald E. Kuykendall
University of Richmond Law Review
The Virginia Constitution mandates that all property within the state, except exempt property, must be taxed. In light of the constitution's directive, this note examines the present Virginia property taxation structure in order to provide the practitioner with a guide to its application and operation.
Partnership Allocations And Tax Reform, Donald J. Weidner
Partnership Allocations And Tax Reform, Donald J. Weidner
Florida State University Law Review
No abstract provided.
Assessing Internal Revenue Service Jeopardy Procedures: Recent Legislative And Judicial Reforms, Margaret M. Armen
Assessing Internal Revenue Service Jeopardy Procedures: Recent Legislative And Judicial Reforms, Margaret M. Armen
Cleveland State Law Review
Recent events have led thoughtful citizens, jurists, and Congressmen to question the wisdom of allowing the Internal Revenue Service (Service) to assess and collect taxes without prior judicial hearing in those instances in which the revenue is thought to be "in jeopardy." Congress and the Supreme Court have made significant reforms which strengthen a taxpayer's rights against Service intransigence or arrogance with respect to jeopardy assessments. The reforms, the abuses which prompted them, and suggestions for future congressional action are the subject of this Note.
Complete Stock Redemption In A Family Corporation: A Warning About The Pitfalls Of Two Standards, Eric T. Johnson
Complete Stock Redemption In A Family Corporation: A Warning About The Pitfalls Of Two Standards, Eric T. Johnson
Villanova Law Review
No abstract provided.