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Articles 1 - 14 of 14
Full-Text Articles in Law
Taxation-Federal Income Tax-Strike Benefits May Be Gifts, Christopher Cobb
Taxation-Federal Income Tax-Strike Benefits May Be Gifts, Christopher Cobb
Michigan Law Review
Taxpayer received assistance from a labor union while he was participating in a strike called by the union. The area in which he lived had become a distressed area as a consequence of the strike, and the union had established a general program of aid for strikers with no other source of income. Both before and after he joined the union payments were made to taxpayer under this program. Taxpayer sued for a refund of the income tax he payed on the value of the assistance so received, and the jury returned a verdict in his favor, finding the payments …
Taxation - Federal Income Tax- Full Payment A Prerequisite To Refund Suit, Stuart S. Gunckel
Taxation - Federal Income Tax- Full Payment A Prerequisite To Refund Suit, Stuart S. Gunckel
Michigan Law Review
A tax deficiency of $28,908.60 including interest was levied by the Commissioner of Internal Revenue against the petitioner for a single tax year. Petitioner paid $5,058.54 but later filed a claim for refund which was disallowed by the Commissioner. On suit by petitioner in a United States district court for the refund, the court held the petitioner was not entitled to the refund because the claimed losses were actually capital in nature. The Court of Appeals for the Tenth Circuit reversed and dismissed the complaint on the ground that the district court could not have jurisdiction until there had been …
Tax—Lease Agreements—Deductibility Of "Rental" Payments As Business Expense, Robert W. Mckisson Jr.
Tax—Lease Agreements—Deductibility Of "Rental" Payments As Business Expense, Robert W. Mckisson Jr.
Washington Law Review
During 1959 two cases involving the right to deduct as an "ordinary and necessary" business expense rental payments made pursuant to equipment lease contracts came before the Courts of Appeals of the Eighth and Ninth Circuits. Both taxpayers claimed the deductions were permissible by authority of section 162 (a) (3) of the 1954 Internal Revenue Code. In both cases the Commissioner of Internal Revenue determined that the "lease" agreements were actually conditional sales contracts, the taxpayer thereby having title to the property, or that with each "rental" payment the taxpayer acquired an equity in the property. The Commissioner disallowed the …
Taxation - Federal Income Tax - Section 355 Held Applicable To The Division Of A Single Business, James N. Adler
Taxation - Federal Income Tax - Section 355 Held Applicable To The Division Of A Single Business, James N. Adler
Michigan Law Review
Petitioner, E. P. Coady, and M. Christopher each owned 50 percent of the stock of the Christopher Construction Co., a corporation engaged for more than five years prior to November 15, 1954, in the conduct of a construction business. On that day the parent, Christopher Company, organized a subsidiary, E. P. Coady & Co., to which it transferred approximately one half of its contracts, equipment, and cash. In exchange, the parent company received all the stock of the subsidiary. Immediately thereafter, the parent distributed to petitioner, one of the two equal shareholders of the parent company, all the stock of …
Taxation, Amount Received For Future Damages, John J. Harrington
Taxation, Amount Received For Future Damages, John J. Harrington
William & Mary Law Review
No abstract provided.
The Income Tax Effect Of Mortgages, John W. Drye, Jr.
The Income Tax Effect Of Mortgages, John W. Drye, Jr.
Washington and Lee Law Review
No abstract provided.
Tax Effects Of Divorce, Marital Separation And Support Agreement, Lester I. Bowman
Tax Effects Of Divorce, Marital Separation And Support Agreement, Lester I. Bowman
William & Mary Law Review
No abstract provided.
Short Term Trusts, John William Hornsby Jr.
Short Term Trusts, John William Hornsby Jr.
William & Mary Law Review
No abstract provided.
Useful Life, Salvage Value, And The 1954 Internal Revenue Code
Useful Life, Salvage Value, And The 1954 Internal Revenue Code
Washington and Lee Law Review
No abstract provided.
Taxation- Federal Income Tax - Deductible Contributions To Nonqualified Profit-Sharing Plans, Robert M. Steed
Taxation- Federal Income Tax - Deductible Contributions To Nonqualified Profit-Sharing Plans, Robert M. Steed
Michigan Law Review
In 1942 plaintiff employer adopted a profit-sharing plan under which a percentage of each year's profits was to be deposited in irrevocable trusts for distribution to its employees in succeeding years. The plan was not "qualified" under the Internal Revenue Code. Although under the terms of the trusts each employee's rights in the fund vested at the time the contribution was made by the employer, these rights would be forfeited by voluntary resignation prior to a fixed date. In 1945 plaintiff deducted the amount contributed to the trust in that year as a contribution to a non-qualified profit-sharing plan under …
The Issuance Of Stock Under Section 1244 Of The Internal Revenue Code, Carle E. Davis
The Issuance Of Stock Under Section 1244 Of The Internal Revenue Code, Carle E. Davis
University of Richmond Law Review
The purpose of this brief note is to examine the provisions of section 1244 with a view toward qualifying for the tax benefits of that section.
Tax Aspects Of Intellectual Property, Lawrence R. Bloomenthal
Tax Aspects Of Intellectual Property, Lawrence R. Bloomenthal
Cleveland State Law Review
Creative activity in the scientific, technical, literary, musical and artistic fields is encouraged by preferential treatment under the income tax laws. While musicians, authors, composers and inventors all receive some special tax benefits, inventors are awarded the most valuable tax breaks.
Taxation In Stockholders' Forgiveness Of Accrued Salaries, Ronald B. Cohen
Taxation In Stockholders' Forgiveness Of Accrued Salaries, Ronald B. Cohen
Cleveland State Law Review
Cancellation of indebtedness ordinarily will be treated as income to a debtor corporation unless the debt was forgiven by a stockholder. In the latter case, the corporation normally treats the resulting benefit as a contribution to capital. However, there is a much more delicate situation when the debt is the result of unpaid salaries, interest, or other corporation expenses. In the typical case, these items would have reduced the income of the corporation in the year of accrual, but would not have been picked up as income by the cash basis stockholder. Therefore, the effective result of forgiveness of salaries …
Taxation - Federal Income Tax - Contract Right Income To Cash Method Taxpayer Who Refused Cash Offer, Eldon Olson
Taxation - Federal Income Tax - Contract Right Income To Cash Method Taxpayer Who Refused Cash Offer, Eldon Olson
Michigan Law Review
During 1951 petitioner, a cash method taxpayer, executed a mineral lease. As part of the consideration petitioner was to receive an unconditional bonus or advance royalty of fixed amount. The lessee was ready, able and willing to pay the entire amount on execution, but at petitioner's request the contract provided for a small payment on execution with one-half the balance due on January 5th of each of the next two years. About one month before each due date the contract rights were discounted at a bank of which petitioner was a director. The lessee remained ready, able and willing to …