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Taxation - Federal Income Tax - Meals And Lodging Under The 1954 Code, John H. Mcdermott
Taxation - Federal Income Tax - Meals And Lodging Under The 1954 Code, John H. Mcdermott
Michigan Law Review
Before discussing the application of the 1954 Internal Revenue Code with regard to the taxability of meals and lodging furnished an employee by his employer, several fundamental tax concepts should be examined. The first of these involves the definition of gross income, which for many years has been cast in broad statutory language. For example, section 22(a) of the 1939 Internal Revenue Code provided that gross income includes " ... gains, profits, and income derived from salaries, wages, or compensation for personal service ... of whatever kind and in whatever form paid .... " Comprehensive as these terms appear, gross …
Taxation - Federal Income Tax - Corporate Accumulations, Stock Dividends And The "Preferred Stock Bail-Out," And Taxability Of The Corporation Upon The Distribution Of "Inventory Assets" Under The Internal Revenue Code Of 1954, Alice Austin S.Ed.
Michigan Law Review
It is the purpose of this discussion to indicate, with respect to corporate accumulations and distributions, some of the major interpretative problems existing under the 1939 code which Congress has failed to resolve, as well as some of the major interpretative difficulties which arise for the first time under the 1954 code.
Taxation - Federal Income Taxation - Problems Created By The Complex Trust Provisions Of The 1954 Code, Harvey A. Howard S.Ed.
Taxation - Federal Income Taxation - Problems Created By The Complex Trust Provisions Of The 1954 Code, Harvey A. Howard S.Ed.
Michigan Law Review
This comment will not be expository of all of the trust provisions but rather will attempt to deal with some of the more important interpretative difficulties likely to be encountered in the new law involving the taxation of the income of those trusts which may accumulate income, distribute corpus, or pay or set aside amounts for charitable purposes. It will be assumed that the reader is familiar with the basic statutory pattern of the trust sections of the new code.
Taxation - Federal Income Tax - Extent To Which A Dividend In Kind Is Ordinary Income Under The Internal Revenue Code, Alice Austin S.Ed.
Taxation - Federal Income Tax - Extent To Which A Dividend In Kind Is Ordinary Income Under The Internal Revenue Code, Alice Austin S.Ed.
Michigan Law Review
Taxpayer, a corporate shareholder, received from the corporation a distribution of property which had appreciated in value over its adjusted cost. The earnings and profits of the corporation were sufficient to cover the adjusted cost of the property distributed, but were not sufficient to cover its full fair market value at the time of distribution. The Tax Court held that the fair market value of the distribution was taxable as a dividend only to the extent of the corporation's earnings and profits. On appeal, held, reversed. In determining whether a distribution in kind is a dividend under section 115(a), …
Michigan Title Examinations And The 1954 Revenue Code's New General Lien Provisions, L. Hart Wright
Michigan Title Examinations And The 1954 Revenue Code's New General Lien Provisions, L. Hart Wright
Michigan Law Review
Title examiners, and more particularly their clients, have long suffered from a controversy-limited almost exclusively to Michigan- involving the methods by which the United States Treasury Department could perfect general federal tax liens. The December 1952 issue of the Michigan Law Review carried an article by the present writer pointing up the irreconcilable difference which has existed for a quarter of a century between the type of record notice which the Treasury was willing to provide prospective bona fide purchasers et al., and the quite different and more demanding type which the Michigan Legislature insisted upon if the local offices …