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Full-Text Articles in Law
Is Consistency The Hobgoblin Of Little Minds? Co-Investment Under Code Section 4941, Elaine Waterhouse Wilson
Is Consistency The Hobgoblin Of Little Minds? Co-Investment Under Code Section 4941, Elaine Waterhouse Wilson
Law Faculty Scholarship
No abstract provided.
Circuit-Specific Application Of The Internal Revenue Code: An Unconstitutional Tax, Jeffrey S. Kinsler
Circuit-Specific Application Of The Internal Revenue Code: An Unconstitutional Tax, Jeffrey S. Kinsler
Law Faculty Scholarship
For all practical purposes, the Constitution prescribes only one limit on the federal government's power to tax: the Uniformity Clause, which requires that indirect taxes, such as income and excise taxes, be "uniform throughout the United States ... " It is exceedingly rare for a federal tax law to violate the Uniformity Clause. The Internal Revenue Code does not fix different taxes for different states, as Congress has carefully crafted the tax laws to avoid geographical distinctions. Unfortunately, the Internal Revenue Service ("IRS") has not always been so careful. In recent years, the IRS has adopted a practice of applying …