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The End Of Cash, The Income Tax, And The Next 100 Years, Gregg D. Polsky, Jeffery H. Kahn
The End Of Cash, The Income Tax, And The Next 100 Years, Gregg D. Polsky, Jeffery H. Kahn
Scholarly Works
The income tax is technologically very similar to the way it was in its early years, and technological developments have been at the margins of the income tax and have not affected its core elements. Still, technological improvements have made third-party reporting and withholding more efficient, which has allowed these mechanisms to become more pervasively used. Technology has also made it easier for taxpayers to substantiate their activities. These changes have facilitated the evolution of the incometax from its original class tax to the mass tax it is today.
While further technological advances might improve the federal income tax, it …
Tax Advice For The Second Obama Administration, Michael J. Graetz
Tax Advice For The Second Obama Administration, Michael J. Graetz
Faculty Scholarship
Delivered January 18, 2013 as the keynote address at a conference cosponsored by Pepperdine Law School and Tax Analysts.
Kite: Irs Wins Qtip Battle But Loses Annuity War, Kerry A. Ryan
Kite: Irs Wins Qtip Battle But Loses Annuity War, Kerry A. Ryan
All Faculty Scholarship
In Kite, the Tax Court held that a 10-year deferred annuity constituted adequate and full consideration for a transfer of family partnership interests, even though the transferor died before receiving any payments. The court also held that the liquidation of a qualified terminable interest property trust and subsequent sale of its assets constituted a disposition of the qualifying income interest for life, resulting in a deemed transfer of the entire trust under section 2519. Ryan discusses those holdings and two more issues that were not raised in the Tax Court proceeding but are clearly implicated by the Kite facts.