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Full-Text Articles in Law
Making Subchapter S Work, Glenn E. Coven
Start-Up Costs, Section 195 And Clear Reflection Of Income: A Tale Of Talismans, Tacked-On Tax Reform And A Touch Of Basics, John W. Lee
Faculty Publications
No abstract provided.
A Policy Analysis Of Fee-Shifting Rules Under The Internal Revenue Code, Gary Myers, Richard L. Schmalbeck
A Policy Analysis Of Fee-Shifting Rules Under The Internal Revenue Code, Gary Myers, Richard L. Schmalbeck
Faculty Publications
Until recently, the costs of litigating federal tax cases were borne exclusively by the parties who incurred them, regardless of whether the government or the taxpayer prevailed in the litigation. This practice reflects the application to tax disputes of the ‘American rule’ against fee shifting. Although the American rule continues to be predominant in the tax area, it has been modified in important respects. An explicit fee-reimbursement rule, benefiting prevailing taxpayers in cases in which the government is found to have acted unreasonably, was added to the Internal Revenue Code (IRC) by the Tax Equity and Fiscal Responsibility Act of …
Book Review Of The Supreme Court And Constitutional Democracy, Neal Devins
Book Review Of The Supreme Court And Constitutional Democracy, Neal Devins
Faculty Publications
No abstract provided.