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Articles 1 - 30 of 31
Full-Text Articles in Law
The Fabled Esop, Robert S. Taft
The Fabled Esop, Robert S. Taft
William & Mary Annual Tax Conference
No abstract provided.
Federal Taxation In Separation And Divorce, Edward S. Graves
Federal Taxation In Separation And Divorce, Edward S. Graves
William & Mary Annual Tax Conference
No abstract provided.
Hobby Farming, Recreational Property And Yachts As Tax Shelters, Peter B. Sang
Hobby Farming, Recreational Property And Yachts As Tax Shelters, Peter B. Sang
William & Mary Annual Tax Conference
No abstract provided.
The "Limitation On Artificial Losses" And Its Impact On Film And Real Estate Tax Shelters, Robert Feinschreiber
The "Limitation On Artificial Losses" And Its Impact On Film And Real Estate Tax Shelters, Robert Feinschreiber
William & Mary Annual Tax Conference
No abstract provided.
The Judicial Public Policy Doctrine In Tax Litigation, Michigan Law Review
The Judicial Public Policy Doctrine In Tax Litigation, Michigan Law Review
Michigan Law Review
This Note evaluates the merits of Revenue Ruling 74-323. First, it asserts that, while not arbitrary, the Service's resolution of the preemption issue was not mandated by the language of amended section 162 or by the relevant legislative history. Second, it maintains that it is both appropriate and procedurally feasible to apply the judicial public policy doctrine to violations of federal civil rights laws that impose no fine, imprisonment, loss of license, or other criminal penalty. The denial of a deduction in this situation would extend the public policy doctrine beyond both section 162(c)(2) and the judicial doctrine as it …
Fisher V. United States, Lewis F. Powell Jr.
Fisher V. United States, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
Bryan V. Itasca County, Minnesota, Lewis F. Powell Jr.
Bryan V. Itasca County, Minnesota, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
Exploring The Role Of Taxation In The Land Use Planning Process, Barry A. Currier
Exploring The Role Of Taxation In The Land Use Planning Process, Barry A. Currier
Indiana Law Journal
No abstract provided.
The Great Section 38 Property Muddle, J. A. Cragwall, Jr.
The Great Section 38 Property Muddle, J. A. Cragwall, Jr.
Vanderbilt Law Review
Twelve full years have elapsed since section 38 property made its first appearance on the stage of tax law. In those twelve years, a complicated, confusing, ad hoc, and often inconsistent body of rulings and judicial decisions has grown up around the definitional regulation; words and phrases have acquired strange new meanings and connotations in the lush overgrowth of legal reasoning clinging to that regulation. The paradoxes in the regulation (such as that addressed in Weirick) and, more often, the ambiguities resulting from an almost universal failure by the regulations to define, instead of simply illustrate, its terms (such as …
The Possession By A Trustee Of The Power To Alter The Time And Manner Of Enjoyment Of Life Insurance Proceeds Held In Trust Requires That The Value Of The Proceeds Be Included In The Decedent Trustee's Gross Estate., Alex Huddleston
St. Mary's Law Journal
Abstract Forthcoming.
Federal Tax Liens--Assignment Of Accounts--The "No Property" Rule Under The 1966 Federal Tax Lien Act And Article 9 Of The Uniform Commercial Code--Nevada Rock & Sand Co. V. United States, Monte N. Stewart
BYU Law Review
No abstract provided.
Tax Planning For Compensation Of Service Partners
Tax Planning For Compensation Of Service Partners
William & Mary Law Review
No abstract provided.
Lehre Und Forschung Im Steurrecht In Den Usa, Hugh Ault
Lehre Und Forschung Im Steurrecht In Den Usa, Hugh Ault
Hugh J. Ault
No abstract provided.
A Study Of The Effects Of The 1969 Tax Reform Act On Private Grant-Making Foundation Support Of Charitable Activities, John S. Lore
A Study Of The Effects Of The 1969 Tax Reform Act On Private Grant-Making Foundation Support Of Charitable Activities, John S. Lore
Dissertations
No abstract provided.
Tax Problems Associated With The Incorporation Of A Partnership: Revenue Ruling 70-239h, Peter Olsen
Tax Problems Associated With The Incorporation Of A Partnership: Revenue Ruling 70-239h, Peter Olsen
Vanderbilt Law Review
The publication of Revenue Ruling 70-239 creates concern with respect to the possible impact of the very broad language of the Ruling in areas not specifically covered. This concern relates to the availability of an ordinary loss deduction under section 1244; various personal holding company and "subchapter S" problems; the impact on section 357(c) and section 1239; the effect on basis computations and the control requirement of section 351; and holding period considerations under section 1223. This article will attempt to examine Revenue Ruling 70-239 with a view to (1) evaluating the accuracy of the conclusion that all three corporation …
Narcotics Offenders And The Internal Revenue Code: Sheathing The Section 6851 Sword, John M. Fite
Narcotics Offenders And The Internal Revenue Code: Sheathing The Section 6851 Sword, John M. Fite
Vanderbilt Law Review
This Note first will analyze the Internal Revenue Code provisions supporting the current crackdown by the IRS on suspected narcotics dealers. Secondly, it will examine the split in the federal circuit courts of appeal on the issues of the availability of Tax Court review of an assessment made pursuant to a section 6851 termination of a taxable year and the availability of equitable or statutory protections to prevent the seizure and sale of property belonging to the taxpayer. Lastly, a discussion of the propriety of such conduct by the IRS and its constitutionality in light of recent Supreme Court decisions …
The Taxpayer's Expectation Of Privacy As A Bar To Production Of Records Held By His Attorney
The Taxpayer's Expectation Of Privacy As A Bar To Production Of Records Held By His Attorney
William & Mary Law Review
No abstract provided.
Income Tax--Corporate Liquidations--Deductability Of Legal Expenses, Gary L. Call
Income Tax--Corporate Liquidations--Deductability Of Legal Expenses, Gary L. Call
West Virginia Law Review
No abstract provided.
Redistributing Wealth By Curtailing Inheritance: The Community Interest In The Rule Against Perpetuities And The Estate Tax, John W. Van Doren
Redistributing Wealth By Curtailing Inheritance: The Community Interest In The Rule Against Perpetuities And The Estate Tax, John W. Van Doren
Florida State University Law Review
No abstract provided.
The Brain Drain: A Tax Analysis Of The Bhagwati Proposal, Richard Pomp
The Brain Drain: A Tax Analysis Of The Bhagwati Proposal, Richard Pomp
Faculty Articles and Papers
For many years, less developed countries (LDCs) have experienced an emigration of their skilled workers to developed countries (DCs), a phenomenon known as the “brain drain”. In response to this issue, Professor Jagdish Bhagwati has proposed a tax on the earnings of professionals, technicians, and kindred persons (PTKs) who emigrate to DCs. This chapter discusses Bhagwati’s proposal, and some alternative proposals. Part 1 explains the “brain drain” problem. Part 2 examines the three main approaches of taxing emigrant PTKs, discusses jurisdictional issues, relief from double taxation, and administrative concerns that arise from these approaches. This section further analyzes Bhagwati’s proposal …
Is Section 6861 The Source Of Authority For Short-Year Jeopardy Assessments Under The Internal Revenue Code?, Steven D. Gold
Is Section 6861 The Source Of Authority For Short-Year Jeopardy Assessments Under The Internal Revenue Code?, Steven D. Gold
Kentucky Law Journal
No abstract provided.
Scope Of Disclosure Of Internal Revenue Communications And Information Files Under The Freedom Of Information Act, Peter R. Spanos
Scope Of Disclosure Of Internal Revenue Communications And Information Files Under The Freedom Of Information Act, Peter R. Spanos
University of Michigan Journal of Law Reform
This article will discuss the proper scope of disclosure under the Freedom of Information Act of the files and administrative and policy materials of the IRS, with particular attention to the following currently contested issues: (1) the extent to which IRS guideline documents and private letter rulings are subject to disclosure; (2) the proper scope of the FOIA exemption for "interagency or intra-agency memorandums or letters which would not be available by law to a party other than an agency in litigation with the agency" as applied to the IRS; and (3) the scope of the exemption for "investigatory records …
The Federal Income Tax Impact Of The Operating Function On The Choice Of Business Form: Partnership, Subchapter C Corporation, Or Subchapter S Corporation, Samuel C. Thompson Jr.
The Federal Income Tax Impact Of The Operating Function On The Choice Of Business Form: Partnership, Subchapter C Corporation, Or Subchapter S Corporation, Samuel C. Thompson Jr.
Journal Articles
No abstract provided.
Household Services And Child Care In The Income Tax And Social Security Laws, William D. Popkin
Household Services And Child Care In The Income Tax And Social Security Laws, William D. Popkin
Indiana Law Journal
No abstract provided.
Realty Shelter Partnerships In A Nutshell, Donald J. Weidner
Realty Shelter Partnerships In A Nutshell, Donald J. Weidner
Scholarly Publications
There continues to be heated discussion about tax reform in the area of real estate tax shelters. In the past few years, the Internal Revenue Service has taken what many feel to be substantively unsupportable moves against the use of real estate partnerships to deliver tax shelter to high bracket investors. The purpose of this Article is to explain the Service's actions against realty partnerships in the context of current manipulations of the partnership form.
The Federal Collection Of State Individual Income Taxes, Nicholas J. Letizia
The Federal Collection Of State Individual Income Taxes, Nicholas J. Letizia
Fordham Urban Law Journal
States have traditionally relied on taxes to finance the expansion of services, and most states have enacted broad-based income taxes which yield additional revenue without raising tax rates. Federal grant-in-aid and revenue sharing funds also increase a state's fiscal resources and relieve pressure for additional taxes. Revenue Sharing was intended to replace restricted grants-in-aid and permit state and local governments to receive federal funds pursuant to an allocation basis which rewarded state and local tax efforts. An unutilized provision of Revenue Sharing provides for the optional piggybacking of state income taxes upon the federal income tax. The Internal Revenue Service …
The Role Of The Corn Products Doctrine In Foreign Exchange Transactions, Charles H. Manning
The Role Of The Corn Products Doctrine In Foreign Exchange Transactions, Charles H. Manning
Vanderbilt Journal of Transnational Law
Exchange rate gain or loss may result from fluctuations of exchange rates or from formal governmental action such as revaluation and devaluation. In evaluating the significance of foreign exchange transactions and their tax consequences, the types of transactions that produce exchange rate gain or loss must be distinguished. The first type of transaction is currency speculation in which exchange rate gain or loss is the only profit or loss realized. The second type of transaction involves the purchase and sale of inventory in which the exchange rate gain or loss is ancillary to the monetary gain or loss realized on …
The Individual Exemption From The Illinois Personal Property Tax, 9 J. Marshall J. Prac. & Proc. 424 (1975), Richard O. Wood
The Individual Exemption From The Illinois Personal Property Tax, 9 J. Marshall J. Prac. & Proc. 424 (1975), Richard O. Wood
UIC Law Review
No abstract provided.
Book Review: Urban Incentive Tax Credits, By Edward M. Meyers And John J. Musial, Phillip Weitzman
Book Review: Urban Incentive Tax Credits, By Edward M. Meyers And John J. Musial, Phillip Weitzman
Fordham Urban Law Journal
The authors of this book propose a tax credit to all individuals and businesses who reside within depressed cities, in an effort to reverse the exodus of middle and upper income individuals from the central cities and induce businesses to undertake new investment within the city. The reviewer observes that there are technical errors and gaps in the authors' analysis, but that the most serious problem is with the general principles underlying their approach. He argues that it is unlikely that the proposed tax credits would actually have the intended effect of revitalizing depressed inner city areas.
Collateral Estoppel: Loosening The Mutuality Rule In Tax Litigation, Michigan Law Review
Collateral Estoppel: Loosening The Mutuality Rule In Tax Litigation, Michigan Law Review
Michigan Law Review
Collateral estoppel is an aspect of the doctrine of res judicata that precludes relitigation of issues previously adjudicated. A judgment in a prior action may be held conclusive as to issues in a subsequent case. even though the later case technically involves a different cause of action. The rule of collateral estoppel seeks to conserve judicial energy, promote confidence in the judicial system, avoid litigant expense, promote community peace and reliance on judgments, and minimize inconsistent results. Countervailing policy concerns are the right of each person to have his day in court, the fear of increased litigation, the danger of …