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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 Mar 1976

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 Jan 1976

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 Jan 1976

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. Jan 1976

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 Jan 1976

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 Jan 1976

Tax Shelters Under The Tax Reform Act Of 1976, Lawrence J. Lee

Villanova Law Review

No abstract provided.