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Articles 1 - 4 of 4
Full-Text Articles in Law
Home Office Deductions: May A Taxpayer Have More Than One Principal Place Of Business?, Michigan Law Review
Home Office Deductions: May A Taxpayer Have More Than One Principal Place Of Business?, Michigan Law Review
Michigan Law Review
This Note argues that the Tax Court's more liberal interpretation is correct because it more nearly reflects Congress's intent. Part I seeks a basis for preferring one of the competing interpretations in the text of section 280A and in the section's legislative history, but finds none. Looking, of necessity, to the purposes that Congress sought to advance with section 280A, Part II argues that those purposes do not demand a restrictive reading of "principal place of business." Such a reading, moreover, would undermine fundamental and longstanding congressional tax policies. In the absence of a more explicit statement of congressional intent, …
The Decline And Fall Of Taxable Income, Glenn E. Coven
The Decline And Fall Of Taxable Income, Glenn E. Coven
Michigan Law Review
After first exploring the intellectual climate that has facilitated the congressional disregard of taxable income, this Article will examine three areas in which taxable income is no longer the exclusive mechanism for allocating the burden of taxation. That examination will outline the undesirable consequences of the decline of taxable income, and demonstrate that Congress need not have disregarded taxable income to secure the desired pattern of taxation. Because the use of multiple rate schedules constitutes the most significant deviation from the concept of taxable income in terms of the number of taxpayers that it affects and the popular resentment against …
Tax-Based Incomes Policy (Tip) As A Alternative To Wage And Price Controls, Steven R. Hunsicker
Tax-Based Incomes Policy (Tip) As A Alternative To Wage And Price Controls, Steven R. Hunsicker
University of Michigan Journal of Law Reform
Part I of this article will evaluate the major arguments opposing such policies against the background of the recent American experience with wage and price controls. Part II, in light of the applicability of these arguments to TIPs, will consider whether some variant of TIP could realize the claimed benefits while minimizing the economic and administrative costs usually associated with wage and price controls.
Stock Redemptions: The Standards For Qualifying As A Purchase Under Section 302(B)., Douglas A. Kahn
Stock Redemptions: The Standards For Qualifying As A Purchase Under Section 302(B)., Douglas A. Kahn
Articles
This Article discusses the requirements of section 302(b) for characterizing a stock redemption as a purchase rather than as a dividend equivalent. The focus is primarily on two issues: (1) whether the election authorized by section 302(c)(2) to waive family attribution rules should be available to an entity such as a trust or estate; and (2) the determination of the standards to be applied in resolving whether a redemption is "not essentially equivalent to a dividend" so that section 302(b)(1) is applicable.