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- Publication
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- William & Mary Annual Tax Conference (9)
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Articles 1 - 30 of 30
Full-Text Articles in Law
Tax Shelter Limitations, Thomas R. Frantz
Tax Shelter Limitations, Thomas R. Frantz
William & Mary Annual Tax Conference
No abstract provided.
Tax Exempt Bond Provisions, Hugh L. Patterson, Guy R. Friddell, William W. Harrison
Tax Exempt Bond Provisions, Hugh L. Patterson, Guy R. Friddell, William W. Harrison
William & Mary Annual Tax Conference
No abstract provided.
Capital Cost Recovery Changes, B. Cary Tolley Iii
Capital Cost Recovery Changes, B. Cary Tolley Iii
William & Mary Annual Tax Conference
No abstract provided.
The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom
The Allocation Of Partnership Income And Loss Under Sec.704, Herschel M. Bloom
William & Mary Annual Tax Conference
No abstract provided.
A Review Of The Provisions Of The Tax Reform Act Of 1986 Relating To Corporate Acquisitions, Samuel C. Thompson Jr.
A Review Of The Provisions Of The Tax Reform Act Of 1986 Relating To Corporate Acquisitions, Samuel C. Thompson Jr.
William & Mary Annual Tax Conference
No abstract provided.
Employee Benefits Legislation- Another Round: The Tough Get Tougher, Mark S. Dray
Employee Benefits Legislation- Another Round: The Tough Get Tougher, Mark S. Dray
William & Mary Annual Tax Conference
No abstract provided.
Current Issues And Developments Involving Sales Or Exchanges Of Real Estate: The Impact Of Tax Reform 1986 On Real Estate Investments And Activities, Robert G. Gottlieb
Current Issues And Developments Involving Sales Or Exchanges Of Real Estate: The Impact Of Tax Reform 1986 On Real Estate Investments And Activities, Robert G. Gottlieb
William & Mary Annual Tax Conference
No abstract provided.
Purchase Price Allocations In Cost Basis Acquisitions: Sections 338 And 1060 Under The 1986 Code, William Rogers, John W. Lee
Purchase Price Allocations In Cost Basis Acquisitions: Sections 338 And 1060 Under The 1986 Code, William Rogers, John W. Lee
William & Mary Annual Tax Conference
No abstract provided.
Corporate Tax Changes In The 1986 Tax Reform Act, Richard E. May
Corporate Tax Changes In The 1986 Tax Reform Act, Richard E. May
William & Mary Annual Tax Conference
No abstract provided.
South Dakota Airplane Tax Hangs By A Technical Thread, Jeffrey S. Lehman
South Dakota Airplane Tax Hangs By A Technical Thread, Jeffrey S. Lehman
Cornell Law Faculty Publications
No abstract provided.
Wimberly V. Labor & Industrial Relations Commission Of Missouri, Lewis F. Powell Jr.
Wimberly V. Labor & Industrial Relations Commission Of Missouri, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
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.
Selected Issues In State Business Taxation, Walter Hellerstein
Selected Issues In State Business Taxation, Walter Hellerstein
Scholarly Works
This Article surveys selected issues in state business taxation. The topics were chosen with the hope that they would be of general interest to the conference for which this Article originally was prepared. The Article therefore eschews the detailed case analysis that typifies much of the law review writing about state and local taxation--including my own--and focuses instead on broader policy and economic questions that those concerned with state business taxation should find no less important. Part II of this Article considers business taxes and state tax incentives. Part III discusses federal and state tax conformity. Part IV addresses a …
Legal Perspectives On The Interstate Incidence And Shifting Of State And Local Taxes, Walter Hellerstein
Legal Perspectives On The Interstate Incidence And Shifting Of State And Local Taxes, Walter Hellerstein
Scholarly Works
Lawyers, especially constitutional lawyers, have long been concerned with the problems associated with the interstate incidence and shifting of state and local taxes. The Constitution has frequently been invoked as a restraint on the states' power to levy taxes on persons, property, or activities outside their borders. Yet the lawyer's view of tax incidence embodied in these constitutional disputes often bears little resemblance to the economist's. In recent years, however, lawyers have sought to import economic concepts of shifting and incidence into the legal analysis of the constitutional limitations on the states' power to export tax burdens to residents of …
Attending To Legal Tender: The Perils Of Structuring Currency Transactions To Avoid Treasury's Reporting Requirements, Leonard R. Rosenblatt, Lawrence S. Feld
Attending To Legal Tender: The Perils Of Structuring Currency Transactions To Avoid Treasury's Reporting Requirements, Leonard R. Rosenblatt, Lawrence S. Feld
Articles & Chapters
No abstract provided.
Looking A Gift-Horse In The Mouth: Some Observations And Suggestions For Improving Internal Revenue Code Section 1244, Henry F. Johnson, Mark W. Cochran
Looking A Gift-Horse In The Mouth: Some Observations And Suggestions For Improving Internal Revenue Code Section 1244, Henry F. Johnson, Mark W. Cochran
Faculty Articles
Most investors who contemplate a new business venture concentrate on the positive financial aspects of the business. Few investors realize that a thorough tax plan for a prospective business must also account for the contingency of failure. Since the failure of a business venture will, in some way, result in a taxable event, the conscientious corporate planner must devise a strategy that will utilize the losses incurred in order to achieve the most advantageous tax result. Internal Revenue Code section 1244 is not new, not particularly complex, and not fraught with misfortune for taxpayers failing to meet its provisions. This …
Efficiency And Income Taxes: The Rehabilitation Of Tax Incentives, Edward A. Zelinsky
Efficiency And Income Taxes: The Rehabilitation Of Tax Incentives, Edward A. Zelinsky
Articles
This Article explores two prominent issues in current legal literature: the propriety of tax incentives in the federal income tax and the use of economic analysis to examine questions of concern to academic lawyers. One premise of this Article is that there is a connection between these two topics.
Federal Tax Reform Act Of 1985: Impacts On Local Government, Senate Committee On Local Government
Federal Tax Reform Act Of 1985: Impacts On Local Government, Senate Committee On Local Government
California Senate
Summary report of the testimony received at the Special Hearing of the Senate Committee on Local Government.
Control Of Public Spending - Approaches To Balanced Budgets In The United States, Canada, And Europe In Comparison, Peter Schaefer
Control Of Public Spending - Approaches To Balanced Budgets In The United States, Canada, And Europe In Comparison, Peter Schaefer
LLM Theses and Essays
The national debt and federal deficit spending has far-reaching economic consequences in the United States and abroad. This thesis focuses on the legal aspects involved in controlling public expenditure, seeking to develop procedural and substantive legal rules to restrain public spending and help balance the federal budget. Since other governments face similar budget concerns, the anti-deficit measures utilized by the governments of Canada, European nations, and U.S. states are examined. The successful measures from these other governments along with improvements to the current federal approach are proposed to optimize the federal approach to the budget crisis.
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 …
Fiduciary Income Taxation And The Holloway Adjustment, Dennis Bires
Fiduciary Income Taxation And The Holloway Adjustment, Dennis Bires
Articles, Chapters in Books and Other Contributions to Scholarly Works
No abstract provided.
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.
Introduction To The Edwin S. Cohen Tax Symposium: An Overview Of Business Taxation, Michael J. Graetz
Introduction To The Edwin S. Cohen Tax Symposium: An Overview Of Business Taxation, Michael J. Graetz
Faculty Scholarship
It is an honor and pleasure for me to be here today to launch this symposium on current tax reform topics in honor of Edwin S. Cohen on the occasion of his retirement from the University of Virginia as Professor of Law. This is the second occasion I have been asked to speak honoring Ed Cohen on his retirement and, knowing him well, I look forward to many more of his retirements in years ahead.
My assignment today is to provide a brief overview of issues in business taxation. I was tempted simply to repeat the program for this symposium, …
The Parenting Tax Penalty: A Framework For Income Tax Reform, Charles O'Kelley
The Parenting Tax Penalty: A Framework For Income Tax Reform, Charles O'Kelley
Faculty Articles
Part I considers the proper tax treatment of out-of-pocket parenting expenses such as the costs incurred in providing food, clothing, shelter, and other goods and services to children for their consumption. Part I first characterizes the principal design alternatives to the present flat dependency deduction. It then examines the dominant accretion definition of income and concludes that the current flat dependency deduction is more consistent with the accretion concept and our actual governing beliefs than any of the alternatives advocated by its critics. Part II considers the tax relevance of imputed income from self-performed services. It explains (1) how the …
The Emasculated Role Of Judicial Precedent In The Tax Court And Internal Revenue Service, Deborah A. Geier
The Emasculated Role Of Judicial Precedent In The Tax Court And Internal Revenue Service, Deborah A. Geier
Law Faculty Articles and Essays
This article examines the Tax Court and the Internal Revenue Service. Part I discusses the structural and decision-making evolution of the Tax Court as well as the most common recommendation for change--the creation of a National Court of Tax Appeals. Part II examines the nonacquiescence practice of the Internal Revenue Service and the current state of the law with respect to intracircuit nonacquiescence. The article concludes that an expanded concept of stare decisis can alleviate many of the problems without the massive structural change entailed in the creation of a National Court of Tax Appeals.
Income Taxation Of Social Security Benefits: Balancing Social Policy With Tax Policy, Christopher R. Hoyt
Income Taxation Of Social Security Benefits: Balancing Social Policy With Tax Policy, Christopher R. Hoyt
Faculty Works
No abstract provided.
The Impact Of The Tax Reform Act Of 1986 On Legal Education And Law Faculty, Christopher R. Hoyt
The Impact Of The Tax Reform Act Of 1986 On Legal Education And Law Faculty, Christopher R. Hoyt
Faculty Works
No abstract provided.
The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt
The Federal Circuit's 1985 Tax Cases: The Exercise Of Equity, William S. Blatt
Articles
No abstract provided.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
All Faculty Scholarship
As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies the tax treatment of the various types of payments that a partnership may make to a withdrawing partner. It introduced the concept of a liquidation of a partnership interest by the partnership itself, as opposed to the sale of that interest to an outsider or to the continuing partners. In some instances it provides tax consequences for continuing and withdrawing partners which are different from those attendant to a sale. It was designed to make the law concerning disposition of partnership interests simpler and …