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Full-Text Articles in Tax Law

Saving The Next Superman: An Alternative Approach To The Taxation Of Copyright Termination Rights, Benjamin Newell Dec 2015

Saving The Next Superman: An Alternative Approach To The Taxation Of Copyright Termination Rights, Benjamin Newell

Journal of Intellectual Property Law

No abstract provided.


Change And Continuity In Fringe Benefit Taxation: Seeking Sense And Sensibility, Richard L. Kaplan, Dawson J. Price Jan 2015

Change And Continuity In Fringe Benefit Taxation: Seeking Sense And Sensibility, Richard L. Kaplan, Dawson J. Price

NYLS Law Review

No abstract provided.


How To Accomplish A Successful Tax-Free Pension Plan Rollover, Steven T. Graham Feb 2013

How To Accomplish A Successful Tax-Free Pension Plan Rollover, Steven T. Graham

Pepperdine Law Review

Advising a client how to accomplish a tax-free rollover from one pension plan to another has been an area of confusion for the general practitioner. In order to end this confusion the author examines recent statutory amendments, Internal Revenue Service rulings and the Employee Retirement Income Security Act. The author then outlines, in conjunction with the recent changes in the law, potential pension plan rollover scenarios that can aid the client. After a thorough discussion of the available rollovers and the benefits and drawbacks of each, the author concludes with a chart designed to provide quick identification of the most …


The Case For The Retention Of The State Death Tax Credit In The Federal Transfer Tax Scheme: "Just Say No" To A Deduction, John M. Janiga, Louis S. Harrison Nov 2012

The Case For The Retention Of The State Death Tax Credit In The Federal Transfer Tax Scheme: "Just Say No" To A Deduction, John M. Janiga, Louis S. Harrison

Pepperdine Law Review

No abstract provided.


Tax Practice In A Circular Revolution: A Review Of Pli's Circular 230 Deskbook, Bridget J. Crawford Oct 2006

Tax Practice In A Circular Revolution: A Review Of Pli's Circular 230 Deskbook, Bridget J. Crawford

All Faculty Scholarship

This short review essay evaluates the Practicing Law Institute's Circular 230 Deskbook by Jonathan G. Blattmachr, Mitchell M. Gans and Damien Rios. For attorneys, accountants and others who "practice" before the IRS, the Circular 230 Deskbook is a masterful analysis and an important guide to the Internal Revenue Service's labyrinthine rules and regulations governing tax penalties, reportable transactions and the conduct of tax practitioners. Most tax attorneys and accountants have reacted to the recent changes to Circular 230 by appending banner notices to all written communications. Without fully understanding the underlying rules, however, a practitioner cannot be sure that a …


Tax Lawyers, Ethical Obligations, And The Duty To The System, Watson May 1999

Tax Lawyers, Ethical Obligations, And The Duty To The System, Watson

Scholarly Works

Perhaps the most elusive area of law is that of legal ethics. While the term itself is easy to define,' the subject all but defies codification because ethics, or morals (the terms are interchangeable), cannot be encapsulated by or in law. This is because law, in general, contains its own standard of validity on which there is usually clear societal consensus. For example, murder, rape, and theft are morally repugnant universally. Hence, punishment for any of these offenses does not impinge upon religious or individual autonomy because there is no ethical freedom to choose whether or not to engage in …


The Changing Meaning Of "Gift": An Analysis Of The Tax Court's Decision In Carson V. Commissioner, Jeffrey Schoenblum Apr 1979

The Changing Meaning Of "Gift": An Analysis Of The Tax Court's Decision In Carson V. Commissioner, Jeffrey Schoenblum

Vanderbilt Law Review

This Article will focus on the Carson case in an effort to identify the emerging meaning, if any, of gift. Following a consideration of the factual background of the case in Part II, Part HI will analyze critically and in-depth each of the five Carson opinions in an effort to decipher the various currents at play and any common ground that may still be shared by a majority of the court. Finally, Part IV will consider the decision's likely consequences and the long-term prospects for a settled meaning for gift, one that is not only workable, as is the case …


The Realization Requirement And Tax Avoidance, E. George Rudolph Apr 1964

The Realization Requirement And Tax Avoidance, E. George Rudolph

Michigan Law Review

Consider, for a moment, the plight of G. E. Hall. During 1947 Hall incurred a gambling debt to the Las Vegas Club variously estimated at between 145,000 and 478,000 dollars. The debt came into the sole ownership of one Binion, a partner in the club, and was eventually settled by Hall transferring to Binion an undivided one-half interest in certain cattle located in Arizona and Montana. Thereafter, Hall and Binion engaged in the ranching business as partners. At this point the Internal Revenue Service came forward with a claim that Hall, in the course of this disastrous chain of events, …