Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

1985

Tax Law

Institution
Keyword
Publication
Publication Type
File Type

Articles 1 - 30 of 61

Full-Text Articles in Law

Divorce: A Taxing Experience, Charles Edward Falk Dec 1985

Divorce: A Taxing Experience, Charles Edward Falk

William & Mary Annual Tax Conference

No abstract provided.


Statutory (Formerly Non-Statutory) Fringe Benefits: New Sec. 132, Jerry J. Mccoy Dec 1985

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 Dec 1985

Disposition Of The Corporation Or The Corporate Business, N. Jerold Cohen

William & Mary Annual Tax Conference

No abstract provided.


The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven Dec 1985

The Federal Income Tax Consequences Of The Admission Of A New Partner After The 1984 Act, Glenn E. Coven

William & Mary Annual Tax Conference

No abstract provided.


Handling Tax Shelter Disputes And Litigation With The Irs, Mortimer Caplin Dec 1985

Handling Tax Shelter Disputes And Litigation With The Irs, Mortimer Caplin

William & Mary Annual Tax Conference

No abstract provided.


Modification Of Divorce Decrees By Virtue Of The 1984 Tax Amendments Relating To Dependency Exemptions, Roger M. Baron Oct 1985

Modification Of Divorce Decrees By Virtue Of The 1984 Tax Amendments Relating To Dependency Exemptions, Roger M. Baron

University of Arkansas at Little Rock Law Review

No abstract provided.


Tax Expenditures And Tax Reform, Allaire U. Karzon Oct 1985

Tax Expenditures And Tax Reform, Allaire U. Karzon

Vanderbilt Law Review

This Review will focus primarily on the conceptual issues affecting the composition of the tax expenditure list and their relevance to current proposals for new tax legislation. In this context,the tax expenditure theory has been preeminently successful in shaping tax reform. The Review will not delve into the other aspect of Surrey's thesis, which calls for executive and congressional action to alter the budget procedure by integrating direct spending programs with the indirect tax expenditure programs and by adopting one amalgamated budget for the purpose of controlling overall federal spending. This facet of the Surrey thesis has not yet gained …


Lawyer Beware: The Use Of Counsel's Statements As Evidence Against His Client In Tax Fraud Cases, Lawrence S. Feld, Leonard R. Rosenblatt Sep 1985

Lawyer Beware: The Use Of Counsel's Statements As Evidence Against His Client In Tax Fraud Cases, Lawrence S. Feld, Leonard R. Rosenblatt

Articles & Chapters

No abstract provided.


Taxation - Deficit Reduction Act Of 1984 - Treatment Of Loans With Below-Market Interest Rates (Section 172) Statute Note., Douglas A. Allison Sep 1985

Taxation - Deficit Reduction Act Of 1984 - Treatment Of Loans With Below-Market Interest Rates (Section 172) Statute Note., Douglas A. Allison

St. Mary's Law Journal

Abstract Forthcoming.


Federal Tax Liens—I.R.S. May Levy Upon The Entire Balance Of A Joint Bank Account When Delinquent Codepositor Has Right Of Withdrawal, David A. Smith Jul 1985

Federal Tax Liens—I.R.S. May Levy Upon The Entire Balance Of A Joint Bank Account When Delinquent Codepositor Has Right Of Withdrawal, David A. Smith

University of Arkansas at Little Rock Law Review

No abstract provided.


An Opportunity Missed: Armco, Inc. V. Hardesty, A Retreat From Economic Reality In Analysis Of State Taxes, C. James Judson, Susan G. Duffy Jun 1985

An Opportunity Missed: Armco, Inc. V. Hardesty, A Retreat From Economic Reality In Analysis Of State Taxes, C. James Judson, Susan G. Duffy

West Virginia Law Review

No abstract provided.


Container Corporation Of America V. Franchise Tax Board: The Supreme Court Encourages Apportionment Taxation, Laura J. Waterland May 1985

Container Corporation Of America V. Franchise Tax Board: The Supreme Court Encourages Apportionment Taxation, Laura J. Waterland

William & Mary Law Review

No abstract provided.


Vii. Tax Mar 1985

Vii. Tax

Washington and Lee Law Review

No abstract provided.


Tax Tips, Frank Doti Feb 1985

Tax Tips, Frank Doti

Frank J. Doti

No abstract provided.


Jackson Reanalyzed: Preventing Tax-Free Escape Upon Transfer Of A Partnership Interest, Michael J. Baader Feb 1985

Jackson Reanalyzed: Preventing Tax-Free Escape Upon Transfer Of A Partnership Interest, Michael J. Baader

William & Mary Law Review

No abstract provided.


The Experience Of The Phillipines In Taxing Its Nonresident Citizens, Richard Pomp Jan 1985

The Experience Of The Phillipines In Taxing Its Nonresident Citizens, Richard Pomp

Faculty Articles and Papers

No abstract provided.


Survey Of The Law And Selected Issues Relating To The Deductibility Of Soil And Water Conservation Expenditures Under Section 175 Of The Internal Revenue Code, Lonnie R. Beard Jan 1985

Survey Of The Law And Selected Issues Relating To The Deductibility Of Soil And Water Conservation Expenditures Under Section 175 Of The Internal Revenue Code, Lonnie R. Beard

Kentucky Law Journal

No abstract provided.


The Tax Effects Of A Shareholder's Post-Incorporation Sale Of Stock: A Reappraisal, Robert I. Keller Jan 1985

The Tax Effects Of A Shareholder's Post-Incorporation Sale Of Stock: A Reappraisal, Robert I. Keller

Faculty Scholarship

No abstract provided.


Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel S. Goldberg Jan 1985

Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel S. Goldberg

Faculty Scholarship

No abstract provided.


A Comparison Of The Merger And Acquisition Provisions Of Present Law With The Provisions In The Senate Finance Committee's Draft Bill, Samuel C. Thompson Jr. Jan 1985

A Comparison Of The Merger And Acquisition Provisions Of Present Law With The Provisions In The Senate Finance Committee's Draft Bill, Samuel C. Thompson Jr.

Journal Articles

No abstract provided.


Internal Revenue Code Section 7701(B): A More Certain Definition Of Resident, Rolf E. Kroll Jan 1985

Internal Revenue Code Section 7701(B): A More Certain Definition Of Resident, Rolf E. Kroll

Penn State International Law Review

The purpose of this Note is four-fold. First, it seeks to articulate the central concepts underlying taxation of nonresidents and residents. In so doing, the discussion endeavors to show the importance of section 7701(b) of the Internal Revenue Code. Second, it attempts to cancas the case law and pertinent regulations and rulings and highlight the ambiguities therein. Third, the discussion will address the essential features of section 7701(b) and illustrate Congress' new approach to the problem of determining resident status for aliens. Finally, the policy implications of 7701(b) are examined and suggestions for further improvement are made.


Computer Software And The Investment Tax Credit, 5 Computer L.J. 347 (1984), Robert W. Mcgee Jan 1985

Computer Software And The Investment Tax Credit, 5 Computer L.J. 347 (1984), Robert W. Mcgee

UIC John Marshall Journal of Information Technology & Privacy Law

No abstract provided.


To Hold Or Not To Hold: Magneson, Bolker, And Continuity Of Investment Under I.R.C. Section 1031, J. Martin Burke, Michael K. Friel Jan 1985

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.


Attribution Of A Multinational Corporation's Net Income: The Position Of Unitary States Regarding Combined Reporting, William D. Dexter Jan 1985

Attribution Of A Multinational Corporation's Net Income: The Position Of Unitary States Regarding Combined Reporting, William D. Dexter

Vanderbilt Journal of Transnational Law

A complex and controversial aspect of state taxation of business income involves the attribution of a multinational corporation's (MNC's) net income. This Article examines the nature and scope of the controversy that stems from the conflicting views of states that promote a unitary taxation system, and MNCs as well as the Department of Treasury (Treasury) that oppose this position. Section IV illustrates why the unitary business principle is currently the only viable, fair, and feasible method available to the states for the geographical assignment of an MNC's net income. Section V analyzes the MNCs' arguments both against worldwide combined reporting …


Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi Jan 1985

Tax Reform During President Reagan’S First Four Years: A Selective Bibliography, Michael G. Chiorazzi

Articles

No abstract provided.


The Acquisitions Proposals And Their Effect On Corporations, Shareholders And Creditors: Reform Of Reorganizations And Liquidations, Peter L. Faber, John Andre Leduc Jan 1985

The Acquisitions Proposals And Their Effect On Corporations, Shareholders And Creditors: Reform Of Reorganizations And Liquidations, Peter L. Faber, John Andre Leduc

San Diego Law Review

Mr. Faber sets the stage for the debate on the need for reform of our present system by summarizing some basic principles of current law, together with the exceptions that developed over the years. Mr. Faber makes the case for re-examination of Subchapter C, as well as other portions of the tax law. Mr. LeDuc seeks a framework within which to construct a tentative answer to the question that this conference is about: must corporate and shareholder income be taxed complexly? Mr. LeDuc suggests that, in order to create a framework to analyze the necessity for complexity in taxation of …


Revenue Ruling 84-132: Sidelined, But Not Forgotten, Nina R. Murphy Jan 1985

Revenue Ruling 84-132: Sidelined, But Not Forgotten, Nina R. Murphy

University of Richmond Law Review

Virtually all colleges and universities have scholarship programs designed to support their athletic teams. The programs are generally in the form of membership clubs which are tax-exempt under section 501(c)(3) of the Internal Revenue Code and therefore eligible to receive donations which provide tax deductions to their patrons. The fact that an organization is an "eligible receiver," however, does not ensure that all payments to it are deductible. For example, the cost of football tickets is not deductible since the purchaser is receiving value for his payment.


Commments: Continuing Vitality Of The "Goods Or Services" Test, Wayne Michael Willoughby Jan 1985

Commments: Continuing Vitality Of The "Goods Or Services" Test, Wayne Michael Willoughby

University of Baltimore Law Review

The term "trade or business" is used frequently throughout the Internal Revenue Code, and the determination of whether a taxpayer's activities constitute a trade or business has a major impact on the applicable tax treatment. Unfortunately, no definition of trade or business is supplied in the Internal Revenue Code, the legislative history, or the Treasury Regulations. Consequently, the courts have been left this task and two different standards for determining trade or business status have emerged. In this comment, the author reviews the history of the term "trade or business, " examines the decisional law, and analyzes the two current …


Tax Policy For Post-Liberal Society: A Flat Tax Inspired Redefinition Of The Purpose And Ideal Structure Of A Progressive Income Tax, Charles O'Kelley Jan 1985

Tax Policy For Post-Liberal Society: A Flat Tax Inspired Redefinition Of The Purpose And Ideal Structure Of A Progressive Income Tax, Charles O'Kelley

Faculty Articles

A flat rate comprehensive federal income tax could be achieved by replacing graduated rates with a single rate that applies to all taxpayers, eliminating many currently available deductions and credits, and treating as taxable income types of economic gain presently excluded from the tax base. The fact that Congress is seriously considering such radical changes makes it appropriate for tax scholars to reconsider longheld beliefs about the ideal structure of an income tax. This article analyzes the characteristics and underlying rationale of a progressive flat rate comprehensive income tax and reconsiders the nature and purpose of a progressive income tax. …


Reading Tea Leaves: The Fifth Amendment And Tax Records, James G. Starkey Jan 1985

Reading Tea Leaves: The Fifth Amendment And Tax Records, James G. Starkey

Loyola University Chicago Law Journal

No abstract provided.