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Articles 1 - 15 of 15
Full-Text Articles in Law
Tax Treatment Of Lump-Sum Distributions From Previously Qualified Employee Pension Plans, Ann Marie Nader
Tax Treatment Of Lump-Sum Distributions From Previously Qualified Employee Pension Plans, Ann Marie Nader
Duke Law Journal
No abstract provided.
Tax Policy For Lovers And Cynics: How Divorce Settlement Became The Last Tax Shelter In America, C. Garrison Lepow
Tax Policy For Lovers And Cynics: How Divorce Settlement Became The Last Tax Shelter In America, C. Garrison Lepow
Notre Dame Law Review
No abstract provided.
Start-Up Costs, Section 195 And Clear Reflection Of Income: A Tale Of Talismans, Tacked-On Tax Reform And A Touch Of Basics, John W. Lee
Faculty Publications
No abstract provided.
Tax Consequences Of Equitable Adjustments, F. Ladson Boyle
Tax Consequences Of Equitable Adjustments, F. Ladson Boyle
South Carolina Law Review
No abstract provided.
No Pain—No Gain—Should Personal Injury Damages Keep Their Tax Exempt Status, Douglas K. Chapman
No Pain—No Gain—Should Personal Injury Damages Keep Their Tax Exempt Status, Douglas K. Chapman
University of Arkansas at Little Rock Law Review
No abstract provided.
Taxpayer Remedies In South Carolina, William J. Quirk
Taxpayer Remedies In South Carolina, William J. Quirk
South Carolina Law Review
No abstract provided.
A Policy Analysis Of Fee-Shifting Rules Under The Internal Revenue Code, Gary Myers, Richard L. Schmalbeck
A Policy Analysis Of Fee-Shifting Rules Under The Internal Revenue Code, Gary Myers, Richard L. Schmalbeck
Faculty Publications
Until recently, the costs of litigating federal tax cases were borne exclusively by the parties who incurred them, regardless of whether the government or the taxpayer prevailed in the litigation. This practice reflects the application to tax disputes of the ‘American rule’ against fee shifting. Although the American rule continues to be predominant in the tax area, it has been modified in important respects. An explicit fee-reimbursement rule, benefiting prevailing taxpayers in cases in which the government is found to have acted unreasonably, was added to the Internal Revenue Code (IRC) by the Tax Equity and Fiscal Responsibility Act of …
The Perils Of Panama--Are United States Employees Of The Panama Canal Commission Exempt From United States Income Taxation?, Pamela P. Bond
The Perils Of Panama--Are United States Employees Of The Panama Canal Commission Exempt From United States Income Taxation?, Pamela P. Bond
Vanderbilt Journal of Transnational Law
Since the enactment of the Panama Canal Treaty (the Treaty) on October 1, 1979, United States citizens employed by the Panama Canal Commission have come to the United States federal courts seeking exemption from income taxation. The Commission employees have based their claims on an executive agreement which accompanied the Treaty. Specifically, they have relied on the language found in article XV of the Agreement in Implementation of Article III of the Panama Canal Treaty (the Implementation Agreement).
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven
Faculty Publications
No abstract provided.
Taxation Of Equine Sales And Exchanges, Martin J. Mcmahon Jr.
Taxation Of Equine Sales And Exchanges, Martin J. Mcmahon Jr.
Kentucky Law Journal
No abstract provided.
Where Tax Reform Went Astray, Charles E. Mclure Jr.
Where Tax Reform Went Astray, Charles E. Mclure Jr.
Villanova Law Review
No abstract provided.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
All Faculty Scholarship
As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies the tax treatment of the various types of payments that a partnership may make to a withdrawing partner. It introduced the concept of a liquidation of a partnership interest by the partnership itself, as opposed to the sale of that interest to an outsider or to the continuing partners. In some instances it provides tax consequences for continuing and withdrawing partners which are different from those attendant to a sale. It was designed to make the law concerning disposition of partnership interests simpler and …
Introduction, Bernard Wolfman
A Critical View Of Traditional Tax Policy Theory: A Pragmatic Alternative, Nancy E. Schurtz
A Critical View Of Traditional Tax Policy Theory: A Pragmatic Alternative, Nancy E. Schurtz
Villanova Law Review
No abstract provided.
Tax Loopholes As Original Sin: Lessons From Tax History, Gerard M. Brannon
Tax Loopholes As Original Sin: Lessons From Tax History, Gerard M. Brannon
Villanova Law Review
No abstract provided.