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Full-Text Articles in Tax Law
Foundations And The Patman Committee Report, John E. Riecker
Foundations And The Patman Committee Report, John E. Riecker
Michigan Law Review
It is the purpose of this article to evaluate the major points of the first, and main, installment of Congressman Patman's Report in the light of existing Internal Revenue Code provisions, Treasury regulations, and the more significant federal court decisions and Internal Revenue Service rulings. While the Report itself is more inclusive, space limitations dictate that this article be confined to section 501(c)(3) organizations-chiefly foundations, tax-exempt funds, and charitable trusts. Although the writer will strive to be objective, it is difficult to avoid some of the political gloss in which the Report is cast and impossible to discuss the ramifications …
Corporations- Allocation Of Subsidiary's Tax Benefit From Consolidated Return, Thomas B. Ridgley
Corporations- Allocation Of Subsidiary's Tax Benefit From Consolidated Return, Thomas B. Ridgley
Michigan Law Review
Defendant parent corporation received from its subsidiary 3,556,992 dollars in tax benefits which had accrued to the subsidiary from filing a consolidated income tax return. By agreement between parent and subsidiary, the profit-making corporation was to pay the losing corporation the savings created by the consolidated return. The working relationship of the two assured the subsidiary profits and the parent losses. Consequently, nearly all tax benefit inevitably flowed to the parent. Plaintiffs, the subsidiary's minority stockholders, sought a refunding of benefits allocated to defendant, claiming that the agreement was unfair and alleging that the defendant, as the subsidiary's majority shareholder, …
Administrative Law-Rate-Making-Authority Of Fpc To Limit Rate Of Return On Tax Reserves Resulting From Liberalized Depreciation, Harry T. Edwards
Administrative Law-Rate-Making-Authority Of Fpc To Limit Rate Of Return On Tax Reserves Resulting From Liberalized Depreciation, Harry T. Edwards
Michigan Law Review
Plaintiff, a natural gas pipeline company, filed a petition for review of a Federal Power Commission ruling in a rate proceeding under section 4(e) of the Natural Gas Act. Plaintiff argued that Congress did not intend tax deferrals arising from liberalized depreciation to be shared by producers and consumers and that, consequently, accumulated tax reserves should be included in the company's rate base at an ordinary rate of return. The FPC ruled that the petitioner could include its tax reserves in the rate base, but that the rate of return on the reserves would be limited to one and one-half …