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Full-Text Articles in Law
Looking A Gift-Horse In The Mouth: Some Observations And Suggestions For Improving Internal Revenue Code Section 1244, Henry F. Johnson, Mark W. Cochran
Looking A Gift-Horse In The Mouth: Some Observations And Suggestions For Improving Internal Revenue Code Section 1244, Henry F. Johnson, Mark W. Cochran
Faculty Articles
Most investors who contemplate a new business venture concentrate on the positive financial aspects of the business. Few investors realize that a thorough tax plan for a prospective business must also account for the contingency of failure. Since the failure of a business venture will, in some way, result in a taxable event, the conscientious corporate planner must devise a strategy that will utilize the losses incurred in order to achieve the most advantageous tax result. Internal Revenue Code section 1244 is not new, not particularly complex, and not fraught with misfortune for taxpayers failing to meet its provisions. This …
The Parenting Tax Penalty: A Framework For Income Tax Reform, Charles O'Kelley
The Parenting Tax Penalty: A Framework For Income Tax Reform, Charles O'Kelley
Faculty Articles
Part I considers the proper tax treatment of out-of-pocket parenting expenses such as the costs incurred in providing food, clothing, shelter, and other goods and services to children for their consumption. Part I first characterizes the principal design alternatives to the present flat dependency deduction. It then examines the dominant accretion definition of income and concludes that the current flat dependency deduction is more consistent with the accretion concept and our actual governing beliefs than any of the alternatives advocated by its critics. Part II considers the tax relevance of imputed income from self-performed services. It explains (1) how the …