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From De Facto To Statutory Exemption: An Analysis Of The Evolution Of Legislative Policy Regarding The Federal Taxation Of Campaign Finance, Jeffrey Schoenblum
From De Facto To Statutory Exemption: An Analysis Of The Evolution Of Legislative Policy Regarding The Federal Taxation Of Campaign Finance, Jeffrey Schoenblum
Vanderbilt Law School Faculty Publications
This article first explores the development of the de facto system of tax exemption and identifies the tensions that led to its demise. The analysis then details the substitution of a statutory structure in place of the traditional informal arrangement and examines the potential present in that structure for substantial IRS interference in the political process.
The Changing Meaning Of "Gift": An Analysis Of The Tax Court's Decision In "Carson V. Commissioner", Jeffrey Schoenblum
The Changing Meaning Of "Gift": An Analysis Of The Tax Court's Decision In "Carson V. Commissioner", Jeffrey Schoenblum
Vanderbilt Law School Faculty Publications
The complexity of detail that characterizes the Internal Revenue Code (Code) has been the subject of intense criticism and only faint praise. Yet, one of the more striking anomalies of the Code is that its often suffocating detail coexists with the sparest definitions of many key terms. The term "gift" is a prime example. Although its meaning plays an instrumental role in income and gift taxation, the Code nowhere defines the term. As a result, the task of fleshing out its meaning has largely fallen on the Treasury, through the issuance of regulations and rulings, and on the courts, which …