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Full-Text Articles in Tax Law
The Irs's Application Of Arbitrage Provisions: Overregulation Of Municipal Finance, Carol L. Gruendel
The Irs's Application Of Arbitrage Provisions: Overregulation Of Municipal Finance, Carol L. Gruendel
Fordham Urban Law Journal
The federal tax exemption afforded to municipal bonds makes them a desirable investment, but the tax exemption is a costly preference in the federal tax system, that has caused a loss of $9.4 billion in federal revenues in the fiscal year of 1981. Legislation has been enacted to regulate the use of the tax exemption for municipal bonds when their issuers engage in arbitrage practices. Arbitrage bonds are defined under Section 103(c) of the Internal Revenue Code as municipal securities which are issued for the purpose of investing the majority of the proceeds in higher yielding securities, or to replace …
Institutional Posture: A Measure For Good Faith In An Irs Summons Enforcement Proceeding, Monice Rosenbaum
Institutional Posture: A Measure For Good Faith In An Irs Summons Enforcement Proceeding, Monice Rosenbaum
Fordham Urban Law Journal
The Internal Revenue Service may use its powers under section 7602 of the Internal Revenue Code to issue administrative summonses to taxpayers and third parties to verify the content of a filed tax return or to prepare a return where none has been filed. Frequent disputes arise between the IRS and taxpayers who claim that its agents have overstepped their section 7602 power. The Supreme Court attempted to clarify the issues surrounding these disputes in United States v. LaSalle National Bank. The Court formulated a two prong test and created an "institutional posture" standard to measure the IRS's good faith. …