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Full-Text Articles in Law
Analysis Of Revenue Ruling 75-292: A Proposal To Allow The Combined Use Of Sections 1031 And 351 Without Destroying The Tax-Free Status Of Either
William & Mary Law Review
No abstract provided.
The Application Of Depletion To Geothermal Resources, Stephen A. Million
The Application Of Depletion To Geothermal Resources, Stephen A. Million
University of Michigan Journal of Law Reform
The energy crisis and the increasing costs of conventional sources of energy have created increased interest in geothermal resources as an alternative energy source. One impediment to the development of geothermal resources is the uncertainty of their status under federal tax law. This note analyzes the application of the depletion provisions of the Internal Revenue Code of 1954 to geothermal resources. Consideration is given to whether geothermal resources are exhaustible, whether they can or should be viewed as heat, and whether heat is a natural deposit or a mineral. Since geothermal resources exist in several forms, and since the depletion …
Section 1244 Small Business Stock - Professional Responsibility Demands Its Use
Section 1244 Small Business Stock - Professional Responsibility Demands Its Use
University of Richmond Law Review
In 1958, Congress added section 1244 to the Internal Revenue Code, which allows ordinary loss treatment for original owners of specified stock in "small business corporations" when such stock is sold, exchanged at a loss, or when the stock becomes worthless. The purpose of section 1244 is to reduce the discrepancy between the tax treatment of losses sustained by corporations and those sustained by proprietorships or partnerships, thereby diminishing the role which tax considerations play in determining whether a business should be conducted in corporate or in unincorporated form. When an unincorporated business sustains an operating loss, such loss is …
The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.
The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.
University of Richmond Law Review
To give and live to give again has always been the American way. Traditionally, Americans contribute to those charitable institutions and associations which effectuate their benevolent, philanthropic desires. Many individuals believe the funding of charitable institutions should be primarily by direct contributions from the private sector as opposed to federal and state government subsidies. This view is supported by the federal income, I gift and estate tax deductions.
Determination Of The Useful Life Of A Taxpayer's Asset For Purposes Of The Federal Income Tax Deduction For Depreciation Using Statistical Methods To Analyze The Facts And Circumstances, Robert E. Anthony
Villanova Law Review
No abstract provided.
Tax Shelters Under The Tax Reform Act Of 1976, Lawrence J. Lee
Tax Shelters Under The Tax Reform Act Of 1976, Lawrence J. Lee
Villanova Law Review
No abstract provided.