Law Commons^™

Revocable, Irrevocable, & Short Term Trusts, Don W. Llewellyn

William & Mary Annual Tax Conference

No abstract provided.

Steuervergünstigungen In Der Bundesrepublik Deutschland Und Den Usa: Einige Vergleichende Begriffliche Aspekte, Hugh Ault

Hugh J. Ault

No abstract provided.

New Incentives For Middle Class Philanthropy: Radical Funding For The Public Good, Samuel M. Loescher

IUSTITIA

The recent expansions in membership and budget of the American Civil Liberties Union and, even more dramatically, the explosive funding by mail of newly-founded Common Cause and Public Citizen, all suggest the presence of evolutionary forces at work in the American political economy that are encouraging a renewal of middle class associations to monitor powerful institutions and to advocate in behalf of the relatively powerless.

The rash of whistle-blowing disclosures of citizen professionals which have alerted us to the multi-billion dollar wastage on C-5As and attack carriers, the existence of My-Lais, the military assemblage of dossiers on 30 million civilians, …

Section 357(C): Some Observations On Tax Effects To The Cash Basis Transferor, Louis A. Del Cotto

Buffalo Law Review

No abstract provided.

The Newcombe Test For Allowing Depreciation On A Converted Residence-A Procrustean Reliance On Statutory Language

Washington and Lee Law Review

No abstract provided.

The Exclusive Nature Of Internal Revenue Code Section 1235: A Forgotten Congressional Policy

Washington and Lee Law Review

No abstract provided.

Constructive Cash Distributions In A Partnership: How And When They Occur, Robert S. Parker Jr., John W. Lee

Faculty Publications

Constructive cash distributions to partners with possible concomitant severe tax impact can occur whenever a partners share of firm or individual liabilities is cut. This reduction of liabilities can be triggered by a variety of typical partnership transactions. Messrs. Parker arid Lee analyze those transactions under which there is the danger of unforeseen taxation and urge extreme caution.

The "Active Business" Test Of § 355: Implications Of A Trilogy Of Revenue Rulings, John W. Lee

Washington and Lee Law Review

No abstract provided.

Involuntary Conversions And § 337 Of The Internal Revenue Code

Washington and Lee Law Review

No abstract provided.

The Taxability Of Educational Grants

Washington and Lee Law Review

No abstract provided.

Basic Corporate Taxation, Stefan F. Tucker

Michigan Law Review

A Review of Basic Corporate Taxation, 2d Ed. by Douglas A. Kahn

The Feasibility Of Adjusting For Inflation In Computing Taxable Income, Dwight Drake

Washington Law Review

This Comment discusses the effect inflation (and deflation) has upon the measurement of taxable income, concluding, in short, that the present standard of measuring income for income tax purposes would be much more equitable if, instead of focusing solely upon the number of dollars received, it accounted for changes in the value of the dollar (as measured by a price index or price indices) by considering the purchasing power of the dollars received. In times of high inflation and in more stable times as well, this new standard for measuring taxable income would have a profound impact on the relative …

Alternative Gains Tax Treatments Of Decedents' Appreciated Capital Assets, D. Allen Grumbine

Vanderbilt Law Review

The present treatment of appreciated assets under section 1014' of the Code permits a great deal of accrued appreciation to escape the income tax. While decedents pay a greater estate tax because asset appreciation swells their estates, they pay no gains tax at death on this accrued appreciation. Moreover, the recipients of the decedent's property generally take a stepped-up basis for the property equal to its fair market value at the time of death. A great deal of criticism has been leveled at this system, and numerous proposals have been made for remedying the situation: imposition of a capital gains …

Implications Of Minority Interest And Stock Restrictions In Valuing Closely-Held Shares, Alan L. Feld

Faculty Scholarship

The federal estate and gift taxes levy on the gratuitous transfer of wealth by both testamentary and lifetime disposition. The amount of the tax depends on the value placed on the property transferred by the decedent or donor. When the property transferred consists of shares of stock in a closely held corporation, there often exists no ready market to help in valuation. As a result, the value of the shares used to compute the federal estate or gift tax must be determined first by appraising the value of the enterprise, and then by allocating some portion of that value to …

The Standards For Enforceability Of John Doe Summonses Of Third Party Records Relating To The Affairs Of Unidentified Taxpayers

Washington and Lee Law Review

No abstract provided.

Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.

Faculty Publications

In the recent Rodman case, the Tax Court has held that a partner newly admitted near year-end must report his share of the full year's partnership profits. Messrs. Lee and Parker analyze the status of retroactive partnership allocations in view of Rodman, the first decision to expressly sanction retroactive allocations of income (and implicitly of losses) to new partners, and reallocations under Section 704.

Catch-269, Cynthia Kappus

Loyola University Chicago Law Journal

No abstract provided.

The United States Interest Equalization Tax, Richard Pomp

Faculty Articles and Papers

The United States Interest Equalization tax is a one-time tax levied on certain foreign securities, proposed by President Kennedy in order to reduce the balance-of-payments deficit by restricting portfolio investment. Although the tax was enacted in 1964 as a short-term measure, it was continually extended and amended. This article explores the contours of the tax.

Prior to the tax, many foreign debt issues were attracting large amounts of capital due to their high interest rates. The IET attempts to equalize the yield of foreign debt issues with domestic debt issues by imposing a tax on the foreign issues and thus …

Federal Invome Tax Discrimination Between Married And Single Taxpayers, Michael W. Betz

University of Michigan Journal of Law Reform

This article explores the present tax rate structure and its implications, considers the historical events and policies which created four separate tax rates, analyzes the tax policies embodied by the different rate treatment of married and single taxpayers, and examines the constitutional problems involved in maintaining the present disparate tax treatment. An alternative tax rate treatment, which will avoid the discrimination inherent in the present system, is suggested.

Demolition Losses In Leasing: Current Or Deferred Federal Income Tax Deductions, Linda Kreer Witt

Loyola University Chicago Law Journal

No abstract provided.

Case Digest, Journal Staff

Vanderbilt Journal of Transnational Law

1. ACT OF STATE ACT OF STATE

Doctrine precludes Payment of Insurance Policy's Cash Surrender Value in Contravention of the Law of the Nation Governing the Contract

2. ADMINISTRATIVE LAW

Secretary of the Interior may suspend Gas and Oil Leases to Conserve Maritime Natural Resources

3. ADMIRALTY

Libel in Rem against Vessel demise Chartered to the United States is not within Court's Jurisdiction under Suits in Admiralty Act when Ship is Outside United States Territorial Waters

Status as Crew Member of and a Relatively Permanent Connection with a Floating Structure required for Recovery Under the Jones Act

Employer may not …

U.S.A.: Recent Internal Service Ruling Restricts Eurodollar Borrowing By United States Companies, Hugh Ault

Hugh J. Ault

No abstract provided.

Germany: Loss Companies, Hugh Ault

Hugh J. Ault

No abstract provided.