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Section 1244 Small Business Stock - Professional Responsibility Demands Its Use
Section 1244 Small Business Stock - Professional Responsibility Demands Its Use
University of Richmond Law Review
In 1958, Congress added section 1244 to the Internal Revenue Code, which allows ordinary loss treatment for original owners of specified stock in "small business corporations" when such stock is sold, exchanged at a loss, or when the stock becomes worthless. The purpose of section 1244 is to reduce the discrepancy between the tax treatment of losses sustained by corporations and those sustained by proprietorships or partnerships, thereby diminishing the role which tax considerations play in determining whether a business should be conducted in corporate or in unincorporated form. When an unincorporated business sustains an operating loss, such loss is …
The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.
The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.
University of Richmond Law Review
To give and live to give again has always been the American way. Traditionally, Americans contribute to those charitable institutions and associations which effectuate their benevolent, philanthropic desires. Many individuals believe the funding of charitable institutions should be primarily by direct contributions from the private sector as opposed to federal and state government subsidies. This view is supported by the federal income, I gift and estate tax deductions.