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Full-Text Articles in Tax Law

Application Of Internal Revenue Code Section 103(C) To Variable Rate Demand Bonds: Purging The Profiteering Potential, Troy M. Hellenbrand Jan 1987

Application Of Internal Revenue Code Section 103(C) To Variable Rate Demand Bonds: Purging The Profiteering Potential, Troy M. Hellenbrand

Fordham Urban Law Journal

This Note analyzes transactions involving VRDBs, to determine whether they comply with the strictures of IRC section 103(c) and, hence, qualify for the tax exemption. Initially, this Note provides an overview of the tax-exempt bond market by examining the factors that led to the development of VRDBs. It then demonstrates how a reasonable interpretation of the language of IRC section 103(c), gleaned from its legislative history and Treasury promulgations, requires that almost all VRDBs lose their tax-exempt status. More specifically, this Note concludes that the inability to calculate the yield for VRDBs creates an impermissible potential to earn arbitrage profits. …


The Referral Fee And The Aba Rules Of Model Conduct: Should States Adopt Model Rule 1.5(E)?, Sheryl Zeligson Jan 1987

The Referral Fee And The Aba Rules Of Model Conduct: Should States Adopt Model Rule 1.5(E)?, Sheryl Zeligson

Fordham Urban Law Journal

This Note examines the history behind DR 2-107 and the reasons for the ABA's adoption of Model Rule 1.5(e). It then analyzes DR 2-107 in depth to determine whether it has been effective in terms of advancing the policies and purposes it was designed to promote. The Note concludes that DR 2-107 is deficient for the following reasons: (1) members of the legal profession oppose and flagrantly violate the rule; (2) except in a few jurisdictions, violators of the rule are rarely prosecuted while even in those jurisdictions that do enforce the rule, the courts are vague in their interpretation …


Targeting Tax Dollars More Efficiently: Proposed Modifications To The 421-A Real Property Tax Exemption, Deborah Ann Konopko Jan 1987

Targeting Tax Dollars More Efficiently: Proposed Modifications To The 421-A Real Property Tax Exemption, Deborah Ann Konopko

Fordham Urban Law Journal

This note discusses Section 421-a of the Real Property Tax Law in New York, which awards a tax exemption to building owners who construct new multi-family housing units under certain conditions. The stated purpose of the statute is to provide safe, habitable dwellings in New York City. This note examines whether 421-a should remain applicable to all multi-family dwellings, including luxury buildings. The author argues that the present standards for granting exemptions represent an inefficient use of tax dollars and that the legislature should limit its application to rental units.