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Full-Text Articles in Law
Statutory (Formerly Non-Statutory) Fringe Benefits: New Sec. 132, Jerry J. Mccoy
Statutory (Formerly Non-Statutory) Fringe Benefits: New Sec. 132, Jerry J. Mccoy
William & Mary Annual Tax Conference
No abstract provided.
Disposition Of The Corporation Or The Corporate Business, N. Jerold Cohen
Disposition Of The Corporation Or The Corporate Business, N. Jerold Cohen
William & Mary Annual Tax Conference
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 …
To Hold Or Not To Hold: Magneson, Bolker, And Continuity Of Investment Under I.R.C. Section 1031, J. Martin Burke, Michael K. Friel
To Hold Or Not To Hold: Magneson, Bolker, And Continuity Of Investment Under I.R.C. Section 1031, J. Martin Burke, Michael K. Friel
UF Law Faculty Publications
This article examines the judicial and administrative development of the two holding requirements under the continuity of investment standards of section 1031 prior to decisions of the Tax Court and the Ninth Circuit in Magneson v. Commissioner and Bolker v. Commissioner, both of which expanded the boundaries of qualified holding and reemphasized the need for guidance from the Treasury or Congress on these issues. Next the article examines the subsequent impact of these decisions. Finally, the article suggests a standard to be followed in the future.