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Articles 301 - 315 of 315
Full-Text Articles in Law
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi
Articles
No abstract provided.
The Supreme Court's Misconstruction Of A Procedural Statute-A Critique Of The Court's Decision In Badaracco, Douglas A. Kahn
The Supreme Court's Misconstruction Of A Procedural Statute-A Critique Of The Court's Decision In Badaracco, Douglas A. Kahn
Articles
When a taxpayer files an honest' federal income tax return for a taxable year, section 6501(a) of the Internal Revenue Code2 limits the period of time during which the Government can assess a tax for that year to a three-year period commencing with the date that the return was filed. The three-year limitations period is extended for an additional three years by section 6501(e)(1)(A) if the taxpayer's return omits properly includible gross income in an amount in excess of twenty-five percent of the gross income that was reported. If a taxpayer fails to file a return for a taxable year …
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Disparate Tax Treatment Of Different Types Of Business Organizations: Where Should We Go From Here?, Douglas A. Kahn
Articles
If several persons wish to join together in a common enterprise in order to pool their capital or labor or some of each, they may choose among a variety of available organizational structures that will serve that purpose. The most common entity forms are partnerships (including joint ventures), corporations, and trusts. While, in its typical structure, each of those entity forms has its own distinct characteristics, the structure of such organizations often is modified by agreement so as to adopt attributes of another type of entity. Because of this, the substantive distinction between entity types is blurred.
Comments On 'Tax Neutrality Between Equity Capital And Debt', Douglas A. Kahn
Comments On 'Tax Neutrality Between Equity Capital And Debt', Douglas A. Kahn
Articles
Professor Andrews' proposals are aimed at eliminating a tax bias that affects a corporation's choice of a method of raising additional capital. Professor Andrews believes that the current tax system favors a corporation which raises capital internally by accumulating its income (or by borrowing) rather than by issuing stock. Professor Andrews seeks a neutral system that permits the choice of the manner in which capital is raised to be made on economic grounds without influence of the tax laws.
An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White
An Essay On The Conceptual Foundations Of The Tax Benefit Rule, Patricia D. White
Articles
A good deal has been written over the past forty-odd years about the tax benefit rule. Over this period the federal courts have decided many cases in which its application has been at issue, and the law journals have published a small but steady stream of commentary on the rule and its manifestations. Last term, in Hillsboro National Bank v. Commissioner, the Supreme Court issued an opinion that focused squarely, and at some length, on the tax benefit rule. Despite this attention, relatively little has been done to examine the conceptual foundations of the tax benefit rule and to …
Introduction, Douglas A. Kahn
Introduction, Douglas A. Kahn
Articles
While the estate and gift tax area has by no means been ignored in the legal literature, it has not been one of the more popular subjects. For that reason, a symposium on transfer taxation would be welcome at any time, but this is an especially propitious moment for one to appear.
United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein
United States Tax Treaty Policy: An Overview, H. David Rosenbloom, Stanley Langbein
Articles
No abstract provided.
Stock Redemptions: The Standards For Qualifying As A Purchase Under Section 302(B)., Douglas A. Kahn
Stock Redemptions: The Standards For Qualifying As A Purchase Under Section 302(B)., Douglas A. Kahn
Articles
This Article discusses the requirements of section 302(b) for characterizing a stock redemption as a purchase rather than as a dividend equivalent. The focus is primarily on two issues: (1) whether the election authorized by section 302(c)(2) to waive family attribution rules should be available to an entity such as a trust or estate; and (2) the determination of the standards to be applied in resolving whether a redemption is "not essentially equivalent to a dividend" so that section 302(b)(1) is applicable.
Extracting Documents And Information From The Internal Revenue Service, Stuart E. Siegel, Stanley I. Langbein
Extracting Documents And Information From The Internal Revenue Service, Stuart E. Siegel, Stanley I. Langbein
Articles
No abstract provided.
Accelerated Depreciation Revisited—A Reply To Professor Blum, Douglas A. Kahn
Accelerated Depreciation Revisited—A Reply To Professor Blum, Douglas A. Kahn
Articles
Professor Blum's comment addresses the proper or neutral tax treatment to be accorded three of the items discussed in my recent article on accelerated depreciation - namely, annuities, prepaid expenses, and exhaustible assets. Blum disputes my analysis in all three cases. While Blum's article is eminently readable, I do not believe that it refutes my earlier work to any extent. In this reply to Professor Blum, I will deal separately with each of the three items he examines. First, however, it is useful to consider the meaning of the term "tax neutrality" and to set forth my views as to …
Accelerated Depreciation—Tax Expenditure Or Proper Allowance For Measuring Net Income?, Douglas A. Kahn
Accelerated Depreciation—Tax Expenditure Or Proper Allowance For Measuring Net Income?, Douglas A. Kahn
Articles
Since the 1950s, it has become fashionable to attack various provisions of the Internal Revenue Code by calling them "subsidies" rather than "proper" means of measuring taxable income. These "subsidies" through Code provisions have come to be referred to as "tax expenditures," a term coined by Professor Stanley Surrey in a speech he made as Assistant Secretary of the Treasury for Tax Policy on November 15, 1967. In that speech, Professor Surrey stated that our tax system often deliberately departs "from accepted concepts of net income," so that by granting exemptions, deductions, and credits that are not appropriate to an …
Mandatory Buy-Out Agreements For Stock Of Closely Held Corporations, Douglas A. Kahn
Mandatory Buy-Out Agreements For Stock Of Closely Held Corporations, Douglas A. Kahn
Articles
A buy-out of a shareholder's stock is a sale of his stock holdings in a specific corporation pursuatnt to a pre-existing contract. In recent years such arrangements have, deservedly, become an increasingly popular planning device for shareholders in closely held corporations; they make it possible to limit the class of potential shareholders, provide liquidity for the estate of a deceased shareholder, and establish a value for stock which has no active market. There are two popular categories of buy-out plans. If the prospective purchaser of a decedent's shares is the corporation that issued them, the plan is called an "entity …
Some Legal Aspects Of Special Assessments, Frank L. Sage
Some Legal Aspects Of Special Assessments, Frank L. Sage
Articles
Taxes have been defined as "the enforced proportional contributions from persons and property levied by the state by virtue of its sovereignty for the support of the government and all public needs." The essential elements that we will notice particularly are two; first, that the contributions are proportional, that is, levied upon all in the same class according to some impartial standard, and second, that taxes can be levied for public purposes only.
Remedies Of Illegal Taxation, Thomas M. Cooley
Remedies Of Illegal Taxation, Thomas M. Cooley
Articles
Taxation is to a nation what the circulation of the blood is to he individual; absolutely essential to life. In ordinary times it is the chief burden which government imposes upon the people, and is likely, therefore, to be the greatest source of discontent. This renders it of the utmost importance that taxation should as nearly as possible be just, and also that it should appear to those who pay it to be just. Absolute justice, however, is unattainable.
Power Of Judiciary To Declare A Law Unconstitutional, Charles A. Kent
Power Of Judiciary To Declare A Law Unconstitutional, Charles A. Kent
Articles
The judiciary has no power to declare a law unconstitutional unless it conflicts with some provision of the State or Federal Constitution. It will be the purpose of this article to show the reasonableness and meaning of this principle.