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Series

1996

Taxation-Federal

Institution
Keyword
Publication

Articles 1 - 17 of 17

Full-Text Articles in Law

Ending The Irs As We Know It: Thoughts From Outside The Beltway, J. Clifton Fleming Jr. Dec 1996

Ending The Irs As We Know It: Thoughts From Outside The Beltway, J. Clifton Fleming Jr.

Faculty Scholarship

No abstract provided.


Recent Developments Affecting Worker Classification Disputes With The Internal Revenue Service, L. Paige Marvel Dec 1996

Recent Developments Affecting Worker Classification Disputes With The Internal Revenue Service, L. Paige Marvel

William & Mary Annual Tax Conference

No abstract provided.


Recent Federal Income Tax Developments, Ira B. Shepard Dec 1996

Recent Federal Income Tax Developments, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


'Complete' Accrual Taxation, Fred B. Brown Oct 1996

'Complete' Accrual Taxation, Fred B. Brown

All Faculty Scholarship

Under the realization rule, accrued gains and losses generally are not taken into account for income tax purposes until a disposition occurs. Thus, the realization rule is responsible for tax deferral, which in turn likely leads to economic inefficiencies and inequities. The realization rule also contributes greatly to the complexity of the federal income tax system by necessitating numerous Internal Revenue Code provisions that address the many consequences arising from the decision to postpone taxation until a disposition occurs.

An alternative to the realization rule is accrual taxation - the inclusion in the tax base of annual increases and decreases in ...


Toward A Tax-Based Explanation Of The Liability Insurance Crisis, Kyle D. Logue Sep 1996

Toward A Tax-Based Explanation Of The Liability Insurance Crisis, Kyle D. Logue

Articles

The so-called liability insurance crisis of 1985 and 1986 transformed the way we think about tort law and about liability insurance markets. The crisis phenomena, which first appeared in late 1984 and lasted until mid-1986, consisted of enormous increases in liability insurance premiums and alarming reductions in the availability of certain types of liability coverage. In the two principal liability lines of insurance (Other Liability and Medical Malpractice), premiums increased by hundreds (in some cases thousands) of percentage points in a matter of months. At the same time, the availability of liability insurance contracted sharply. The liability policies that were ...


Irs Overhauls Spin-Off Ruling Guidelines, Stuart M. Finkelstein, Stuart G. Lazar Jun 1996

Irs Overhauls Spin-Off Ruling Guidelines, Stuart M. Finkelstein, Stuart G. Lazar

Journal Articles

No abstract provided.


Reflections On Executive Compensation And A Modest Proposal For (Further) Reform, Mark J. Loewenstein Jan 1996

Reflections On Executive Compensation And A Modest Proposal For (Further) Reform, Mark J. Loewenstein

Articles

No abstract provided.


Of Fairness And Might: The Limits Of Sovereign Power To Tax After Winstar, Leo P. Martinez Jan 1996

Of Fairness And Might: The Limits Of Sovereign Power To Tax After Winstar, Leo P. Martinez

Faculty Scholarship

No abstract provided.


The Plethora Of Consumption Tax Proposals: Putting The Value Added Tax, Flat Tax, Retail Sales Tax, And Usa Tax Into Perspective, Alan Schenk Jan 1996

The Plethora Of Consumption Tax Proposals: Putting The Value Added Tax, Flat Tax, Retail Sales Tax, And Usa Tax Into Perspective, Alan Schenk

Law Faculty Research Publications

No abstract provided.


Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas Jan 1996

Customary International Law And State Taxation Of Corporate Income: The Case For The Separate Accounting Method, Chantal Thomas

Cornell Law Faculty Publications

No abstract provided.


Eisenhower-Era Marxist-Confiscatory Taxation: Requiem For The Rhetoric Of Rate Reduction For The Rich, Marc Linder Jan 1996

Eisenhower-Era Marxist-Confiscatory Taxation: Requiem For The Rhetoric Of Rate Reduction For The Rich, Marc Linder

College of Law Publications

No abstract provided.


The Excludability Of Employment Discrimination Awards Under Code Section 104(A)(2) After Burke V. United States And Commissioner V. Schleier, Leandra Lederman Jan 1996

The Excludability Of Employment Discrimination Awards Under Code Section 104(A)(2) After Burke V. United States And Commissioner V. Schleier, Leandra Lederman

Articles by Maurer Faculty

No abstract provided.


The American Dream In Legislation: The Role Of Popular Symbols In Wealth Tax Policy, William Blatt Jan 1996

The American Dream In Legislation: The Role Of Popular Symbols In Wealth Tax Policy, William Blatt

Articles

No abstract provided.


"Civil"Lzing Tax Procedure: Applying General Federal Learning To Statutory Notices Of Deficiency, Leandra Lederman Jan 1996

"Civil"Lzing Tax Procedure: Applying General Federal Learning To Statutory Notices Of Deficiency, Leandra Lederman

Articles by Maurer Faculty

Tax procedure has been rather isolated from the main currents of civil procedure. Using the statutory notice of deficiency as an exemplar, the article explores how viewing tax procedure issues from the perspective of general civil litigation can facilitate procedural regularity and foster fairness to United States Tax Court contestants. The statutory notice is the document by which the IRS forewarns a taxpayer of impending assessment of tax greater than the amount reported on the taxpayer's return. The article identifies three functions of the notice and their general civil litigation analogues. First, like legal process, it provides the taxpayer ...


An Analysis Of The Disallowance Of Advertising Expenses For Tobacco Products, Ravi Mannam Jan 1996

An Analysis Of The Disallowance Of Advertising Expenses For Tobacco Products, Ravi Mannam

LLM Theses and Essays

Generally, reasonable expenses incurred in the ordinary and necessary course of a legitimate trade or business are deductible from gross income under the U.S. Tax Code; however in an effort to curb tobacco use, recent legislation has disallowed this benefit to tobacco companies for advertising expenses. The judiciary has upheld this disallowance under the doctrine of legislative grace. This thesis critiques the doctrine of legislative grace along with a review Congress’s power to tax income and the role of deductions. Also, the possibility of disallowing business expenses under public policy grounds is examined, and the relationship between lobbying ...


Tax Transitions, Opportunistic Retroactivity, And The Benefits Of Government Precommitment, Kyle D. Logue Jan 1996

Tax Transitions, Opportunistic Retroactivity, And The Benefits Of Government Precommitment, Kyle D. Logue

Articles

What if the current federal income tax laws were repealed and replaced with a simple flat tax? What if the entire Internal Revenue Code (with its graduated rates and countless deductions, exclusions, and credits) were scuttled in favor of a broad-based consumption tax? Only a few years ago, such proposals would have seemed radical and extremely unlikely to be adopted. But times are changing. Calls for a drastic overhaul of the Internal Revenue Code have become commonplace, even at the highest levels in the tax-policy community. In addition, proposals that would replace the income tax with a flat-rate broad-based consumption ...


Theories Of The Corporation And The Tax Treatment Of Corporate Philanthropy Symposium: Corporate Philanthropy Law, Culture, Education, And Politics, Linda Sugin Jan 1996

Theories Of The Corporation And The Tax Treatment Of Corporate Philanthropy Symposium: Corporate Philanthropy Law, Culture, Education, And Politics, Linda Sugin

Faculty Scholarship

This essay is organized as follows: Part I describes the entity model of the corporation as developed in corporate and ethical theory, showing how that model is embodied in the Code and how variations in that model produce different conclusions about the legitimacy of the charitable contribution deduction for corporations. It discusses some issues that arise when corporate philanthropy is considered in the context of the entity theory and how the tax law might respond to those issues. Part II explains how the nexus-of-contracts conception of the corporation, applied as an analytical tool, challenges the tax law's treatment of ...