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Full-Text Articles in Law
Merger Is Indirect Gift In Cavallaro, Kerry A. Ryan
Merger Is Indirect Gift In Cavallaro, Kerry A. Ryan
All Faculty Scholarship
In Cavallaro v. Commissioner, the Tax Court held that a merger of two family-owned businesses resulted in a substantial taxable gift. The taxpayers avoided penalties by demonstrating that they relied in good faith on the mistaken advice of competent tax advisers.
A Simpler Verifiable Gift Tax, Wendy G. Gerzog
A Simpler Verifiable Gift Tax, Wendy G. Gerzog
All Faculty Scholarship
The purpose of this article is to propose a simpler verifiable gift tax, to reassert basic principles of transfer taxes, to encourage simple, outright gifts, and to eliminate some of the major abuses in the current gift tax regime. To accomplish these goals, the proposed tax would simplify gift completion rules, adopt a hard-to-complete rule of transfer taxation, reduce the annual exclusion while expanding the consumption exclusion, and employ loss of preference inducements to increase gift tax compliance.