Open Access. Powered by Scholars. Published by Universities.®
- Institution
- Keyword
-
- Accrual (1)
- Bad debt deduction (1)
- Death tax (1)
- Debt financing (1)
- Debt security (1)
-
- Deductibility (1)
- Deduction (1)
- Dividend (1)
- Estate tax (1)
- Executor (1)
- Existing business (1)
- Formula clauses (1)
- Future earnings capacity (1)
- Gross pay (1)
- Income tax (1)
- Income tax deductions (1)
- Indebtedness (1)
- Intent (1)
- Johnson v. Commissioner (1)
- Jury award (1)
- Jury instructions (1)
- Kraft Foods Co. v. Commissioner (1)
- Loewi v. Ryan (1)
- Marital tax benefits (1)
- Marital tax deduction (1)
- Multiple entitities (1)
- Rental (1)
- Reserve fund (1)
- Shareholder property (1)
- Shoemaker-Nash Inc. (1)
- Publication
- Publication Type
Articles 1 - 10 of 10
Full-Text Articles in Law
Federal Tax Liens, Rex M. Walker
Federal Tax Liens, Rex M. Walker
Washington Law Review
The purpose of this comment is to set out the basic statutory law on which the federal tax lien is founded, to examine the scope of the federal tax lien and its relative priority, and to indicate some of the precautions that can be taken to protect a credit transaction from it.
Putnam V. Commissioner—The Reimbursable Outlay Under The Tax Law, Ernest J. Brown
Putnam V. Commissioner—The Reimbursable Outlay Under The Tax Law, Ernest J. Brown
Buffalo Law Review
Putnam v. Comm'r, 352 U. S. 82 (1956), affg Putnam v. Comm'r, 224 F. 2d 947 (8th Cir. 1955).
Taxation - Income Tax - Accurabilty Of Dealer Reserves Withheld By Finance Company, A. Duncan Whitaker S.Ed.
Taxation - Income Tax - Accurabilty Of Dealer Reserves Withheld By Finance Company, A. Duncan Whitaker S.Ed.
Michigan Law Review
Petitioner, a dealer in new and used trailers, had agreements with several finance companies whereby they agreed to buy promissory notes he received on installment sales. The agreements permitted the finance company to withhold a portion of the unpaid balance on each note and credit such amount to the petitioner's "dealer reserve" account. The petitioner was liable for all notes in default and the finance company could charge the reserve with any unpaid balance. The reserve could also be charged with any debts of the petitioner to the company. Periodically, the dealer was to receive portions of the reserve in …
Income Tax - Non-Business Bad Debt Deduction - Deduction For Partially Secured Bad Debt Deferable Until Liquidation Of Collateral Regardless Of Tax Avoidance Motive, Robert H. Elliott Jr.
Income Tax - Non-Business Bad Debt Deduction - Deduction For Partially Secured Bad Debt Deferable Until Liquidation Of Collateral Regardless Of Tax Avoidance Motive, Robert H. Elliott Jr.
Michigan Law Review
In 1944 the taxpayer liquidated security held for a non-business debt and deducted the balance of the debt as worthless. The creditor had been insolvent for some time. The commissioner disallowed the deduction on the grounds that the taxpayer had held the security after the debt was worthless in order to obtain a larger tax benefit from the deduction. The district court upheld the Commissioner. On appeal, held, reversed. A partially secured debt is not worthless as long as security is available for its satisfaction. The taxpayer's intent is not a factor in determining worthlessness. Loewi v. Ryan, …
Tax Aspects Of Jury Valuation Of Future Earnings, John J. Kennett
Tax Aspects Of Jury Valuation Of Future Earnings, John J. Kennett
Cleveland State Law Review
Whether or not a jury should be instructed, in a personal injury case, that its verdict is exempt from federal income taxation, has been much discussed recently. A most practical element in this problem is the difference between "gross pay" and "take-home pay" in computing the present value of future earnings, when estimating damages. The real question presented by the topic concerns impairment, or deprivation, of future earning capacity. Some of the early English cases which I shall mention considered earnings lost between the time of injury and the time of trial, in addition to the impairment of future earning …
Taxation Of Partners And Partnerships Under 1954 Code, W. Lewis Roberts
Taxation Of Partners And Partnerships Under 1954 Code, W. Lewis Roberts
Kentucky Law Journal
No abstract provided.
Tax Considerations In Organizing A Corporation, Marvin D. Kelner
Tax Considerations In Organizing A Corporation, Marvin D. Kelner
Cleveland State Law Review
It is almost impossible, and certainly impractical, to prepare a definitive checklist of incorporation procedures, which will guarantee complete safeguard for all of the "watchdog sections" of the present Internal Revenue Code and further guarantee the lowest tax burden for the corporation and its stockholders. The most that any careful lawyer can do is to apply known and foreseeable procedures, which have been tried and tested in the courts, to any particular company he is engaged in incorporating.
State And Federal Taxation: Tax Problems Of Formula Type Of Marital Deduction Bequest, Byron E. Bronston
State And Federal Taxation: Tax Problems Of Formula Type Of Marital Deduction Bequest, Byron E. Bronston
Articles by Maurer Faculty
No abstract provided.
Elections And Discretions Under The Code: The Executor's Dilemma, Byron E. Bronston
Elections And Discretions Under The Code: The Executor's Dilemma, Byron E. Bronston
Articles by Maurer Faculty
No abstract provided.
Taxation - Federal Income Tax Deductibility Of Interest On Debentures Issues As A Dividend, Jules M. Perlberg
Taxation - Federal Income Tax Deductibility Of Interest On Debentures Issues As A Dividend, Jules M. Perlberg
Michigan Law Review
Taxpayer, a wholly-owned subsidiary corporation, had filed consolidated returns with its parent prior to 1934. When Congress abolished consolidated returns in that year, the subsidiary issued 6% debentures as a dividend to the parent company and subsequently deducted the interest paid on these bonds. The Commissioner claimed the interest payments were really dividends and were not deductible. The Tax Court upheld the Commissioner pointing out the tax-saving motive, absence of new investment, and parent-subsidiary relationship as factors indicating that no genuine debtor-creditor relationship existed. On appeal, held, reversed. The debentures involved were conventional in form and created a valid …