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Full-Text Articles in Law
Unauthorized Tax Elections, Jay A. Soled
Unauthorized Tax Elections, Jay A. Soled
Buffalo Law Review
Unauthorized tax elections are those devices and techniques that taxpayers employ to achieve sought-after objectives but that are not specifically endorsed under the Internal Revenue Code. Often evolving over time, they are a common feature of the nation’s tax system. While unauthorized tax elections can prove subversive, in many instances, if properly and timely addressed, their existence can produce salutary benefits vis-à-vis their eradication or formal institutionalization.
This analysis explores the general contours of unauthorized tax elections and the critical signaling roles that they provide, alerting Congress and the Treasury Department to shortcomings and vulnerabilities in the Internal Revenue Code’s …
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Abandoning Realization And The Transition Tax: Toward A Comprehensive Tax Base, Henry Ordower
Buffalo Law Review
No abstract provided.
Failed Charity: Taking State Tax Benefits Into Account For Purposes Of The Charitable Deduction, Roger Colinvaux
Failed Charity: Taking State Tax Benefits Into Account For Purposes Of The Charitable Deduction, Roger Colinvaux
Buffalo Law Review
The Tax Cuts and Jobs Act (TCJA) substantially limited the ability of individuals to deduct state and local taxes (SALT) on their federal income tax returns. Some states are advancing schemes to allow taxpayers a state tax credit for contributions to a charity controlled by the state. The issue is whether state tax benefits are deductible as a charitable contribution for purposes of the federal income tax. Under a general rule of prior law—the full deduction rule—state tax benefits were ignored for purposes of the charitable deduction. If the full deduction rule is applied to the state workaround schemes, then …
Debt Discharge Income: Kirby Lumber Co. Revisited Under The "Transactional Equity" Rule Of Hillsboro, Louis A. Del Cotto
Debt Discharge Income: Kirby Lumber Co. Revisited Under The "Transactional Equity" Rule Of Hillsboro, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
An Argument For Current Deductability Of A Target's Expenses In A "Friendly" Takeover, Charles A. Lofaso
An Argument For Current Deductability Of A Target's Expenses In A "Friendly" Takeover, Charles A. Lofaso
Buffalo Law Review
No abstract provided.
Spin-Offs Before And After The Tax Reform Act, Donald F. Brosnan
Spin-Offs Before And After The Tax Reform Act, Donald F. Brosnan
Buffalo Law Review
No abstract provided.
Class Tax To Mass Tax: The Role Of Propaganda In The Expansion Of The Income Tax During World War Ii, Carolyn C. Jones
Class Tax To Mass Tax: The Role Of Propaganda In The Expansion Of The Income Tax During World War Ii, Carolyn C. Jones
Buffalo Law Review
No abstract provided.
Interest-Free Loans And Dickman V. Commissioner: A Letter To The Supreme Court, Louis A. Del Cotto, Kenneth F. Joyce
Interest-Free Loans And Dickman V. Commissioner: A Letter To The Supreme Court, Louis A. Del Cotto, Kenneth F. Joyce
Buffalo Law Review
No abstract provided.
Re-Examining The Sham Doctrine: When Should An Overpayment Be Reflected In Basis?, Mitchell M. Gans
Re-Examining The Sham Doctrine: When Should An Overpayment Be Reflected In Basis?, Mitchell M. Gans
Buffalo Law Review
No abstract provided.
The Double Jeopardy Of Corporate Profits, Constantine N. Katsoris
The Double Jeopardy Of Corporate Profits, Constantine N. Katsoris
Buffalo Law Review
No abstract provided.
Tax Superiority In Bankruptcy—A Study Of Business Bankruptcy Distributions In The Southern And Western Districts Of New York, Peter D. Wolfson
Tax Superiority In Bankruptcy—A Study Of Business Bankruptcy Distributions In The Southern And Western Districts Of New York, Peter D. Wolfson
Buffalo Law Review
No abstract provided.
Sales And Other Dispositions Of Property Under Section 1001: The Taxable Event, Amount Realized And Related Problems Of Basis, Louis A. Del Cotto
Sales And Other Dispositions Of Property Under Section 1001: The Taxable Event, Amount Realized And Related Problems Of Basis, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
The Continued Vaildity Of The Supreme Court's Broad Approach To Income In James V. United States, William B. Barker
The Continued Vaildity Of The Supreme Court's Broad Approach To Income In James V. United States, William B. Barker
Buffalo Law Review
No abstract provided.
Section 357(C): Some Observations On Tax Effects To The Cash Basis Transferor, Louis A. Del Cotto
Section 357(C): Some Observations On Tax Effects To The Cash Basis Transferor, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
Sexism In The Code: A Comparative Study Of Income Taxation Of Working Wives And Mothers, Grace Blumberg
Sexism In The Code: A Comparative Study Of Income Taxation Of Working Wives And Mothers, Grace Blumberg
Buffalo Law Review
No abstract provided.
Taxation—Tax Benefit Rule Applicable To Section 357 Liquidations, Thomas A. Palmer
Taxation—Tax Benefit Rule Applicable To Section 357 Liquidations, Thomas A. Palmer
Buffalo Law Review
Commissioner v. Anders, 414 F.2d 1283 (10th Cir. 1969).
Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton
Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton
Buffalo Law Review
Bingler v. Johnson, 394 U.S. 741 (1969).
Taxation—Tax Avoidance Need Only Be One Of The Purposes For Imposition Of The Accumulated Earnings Tax, Jerome M. Hesch
Taxation—Tax Avoidance Need Only Be One Of The Purposes For Imposition Of The Accumulated Earnings Tax, Jerome M. Hesch
Buffalo Law Review
United States v. The Donruss Company, 393 U.S. 297 (1969).
Taxation—Kimbell-Diamond Still Available As An Adjunct To Section 334(B)(2)., Harry Sushek
Taxation—Kimbell-Diamond Still Available As An Adjunct To Section 334(B)(2)., Harry Sushek
Buffalo Law Review
American Potash and Chemical Corp. v. United States, 399 F.2d 194 (Ct. Cl. 1968).
Taxation—“Overnight Rule" Of Commissioner Of Internal Revenue Service Is Valid Under § 162(A)(2) Of Int. Rev. Code Of 1954, Mary E. Bisantz
Taxation—“Overnight Rule" Of Commissioner Of Internal Revenue Service Is Valid Under § 162(A)(2) Of Int. Rev. Code Of 1954, Mary E. Bisantz
Buffalo Law Review
United States v. Correll, 389 U.S. 299 (1967).
Federal Taxation—Effect Of A State Court Adjudication Of Property Rights In Subsequent Federal Tax Litigation, Michael R. Mcgee
Federal Taxation—Effect Of A State Court Adjudication Of Property Rights In Subsequent Federal Tax Litigation, Michael R. Mcgee
Buffalo Law Review
Commissioner v. Estate of Bosch, 387 U.S. 456 (1967).
The Deductibility Of Educational Expenses: Administrative Construction Of Statute, Richard C. Spencer
The Deductibility Of Educational Expenses: Administrative Construction Of Statute, Richard C. Spencer
Buffalo Law Review
No abstract provided.
Assumption And Discharge Of Seller's Liabilities As Year Of Sale Payments For Purposes Of I.R.C. Section 453, David C. Horan
Assumption And Discharge Of Seller's Liabilities As Year Of Sale Payments For Purposes Of I.R.C. Section 453, David C. Horan
Buffalo Law Review
No abstract provided.
Federal Tax Policy In The 1960'S, Stanley S. Surrey
Federal Tax Policy In The 1960'S, Stanley S. Surrey
Buffalo Law Review
No abstract provided.
The Holding Company As A Collapsible Corporation Under Section 341 Of The Internal Revenue Code, Louis A. Del Cotto
The Holding Company As A Collapsible Corporation Under Section 341 Of The Internal Revenue Code, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
The Imputed Sale And Anticipatory Assignment Of Income Doctrines: Their Effect On Irc §§ 311 & 336, Thomas L. David
The Imputed Sale And Anticipatory Assignment Of Income Doctrines: Their Effect On Irc §§ 311 & 336, Thomas L. David
Buffalo Law Review
No abstract provided.
Taxation—Bad Debts: Limitations Of The “Promoter Doctrine”, Ronald B. Felman
Taxation—Bad Debts: Limitations Of The “Promoter Doctrine”, Ronald B. Felman
Buffalo Law Review
No abstract provided.
Sale Of Endowment Policy To Avoid Ordinary Tax Treatment, Richard Attea
Sale Of Endowment Policy To Avoid Ordinary Tax Treatment, Richard Attea
Buffalo Law Review
Commissioner v. Phillips, 275 F.2d 33 (4th Cir. 1960).
Excludability Of Quarters Allowance From Gross Income For Tax Purposes, Herbert Blumberg
Excludability Of Quarters Allowance From Gross Income For Tax Purposes, Herbert Blumberg
Buffalo Law Review
Boykin v. Commissioner of Internal Revenue, .__ F.2d __, CCH 1958 STAND. FED. TAX REP. (58-2 U.S. Tax Cas.) 119900 (8th Cir. Oct. 30, 1958).
Fellowships Grants Under The Internal Revenue Code Of 1954, Eugene Salisbury
Fellowships Grants Under The Internal Revenue Code Of 1954, Eugene Salisbury
Buffalo Law Review
Wrobleski v. Bingler, 58-2 U.S.T.C. -, 161 Fed. Supp. 901 (1958).