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Full-Text Articles in Law
Penalizing Bribery Of Foreign Officials Through The Tax Laws: A Case For Repealing Section 162 (C)(1), Christopher Alan Lewis
Penalizing Bribery Of Foreign Officials Through The Tax Laws: A Case For Repealing Section 162 (C)(1), Christopher Alan Lewis
University of Michigan Journal of Law Reform
Most commentary on these congressional attempts to use tax laws to control the ethics of overseas enterprises has centered either on the effectiveness of these provisions or on the burdens and difficulties involved with their implementation. This article, while discussing these issues, is concerned primarily with the conceptual justifications and the direct economic effects of these tax provisions. The article contends that section 162(c)(1) and the pertinent provisions of the Tax Reform Act of 1976 are disguised penalties which often operate arbitrarily and unfairly and concludes that they should be repealed in favor of more equitable and effective deterrents.
Taxpayer Rights In Noncustodial Irs Investigations After Beckwith V. United States, Curtis L. Christensen
Taxpayer Rights In Noncustodial Irs Investigations After Beckwith V. United States, Curtis L. Christensen
University of Michigan Journal of Law Reform
The recent Supreme Court decision in Beckwith v. United States, holding that Miranda does not extend to noncustodial tax investigations, has important implications with respect to the News Release doctrine and the involuntary consent grounds considered in motions to suppress evidence. This article will examine Beckwith and its potential significance with respect to these other doctrines, discussing the factors which the IRS and the courts should consider in order to assure fair treatment of taxpayers during investigations.