Tax Law Commons^™

Tax Planning Enhanced By Tax-Free Exchange Provisions, Thomas R. Frantz

William & Mary Annual Tax Conference

No abstract provided.

Divorce And Separation: Income Tax Consequences, Barbara B. Lewis

William & Mary Annual Tax Conference

No abstract provided.

Recent Legislative Developments And Proposals, Mark L. Mcconaghy

William & Mary Annual Tax Conference

No abstract provided.

Choice Of Entities For Holding Real Estate: Real Estate Investment Trusts, John Schwieters

William & Mary Annual Tax Conference

No abstract provided.

Choice Of Entities For Holding Real Estate: Historical Structures And Low Income Housing, Bruce S. Lane

William & Mary Annual Tax Conference

No abstract provided.

Choice Of Entities For Holding Real Estate: Partnerships, Alan J.B. Aronsohn

William & Mary Annual Tax Conference

No abstract provided.

Choice Of Entities For Holding Real Estate: Corporations, Leonard L. Silverstein

William & Mary Annual Tax Conference

No abstract provided.

Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles

Vanderbilt Law Review

This Note first will set forth the Treasury Department's perception of the present abuses of tax shelter partnerships and will analyze existing procedural rules, the Treasury Department's proposed amendments, and the House of Representatives' proposed amendments in light of these abuses. Next, the Note will examine the substantive law of Subchapter K and will attempt to point out the probable effects of the proposed amendments on the aggregate concept of partnerships, on substantive partnership tax law, and on the viability of the partnership form of business. Finally, this Note will propose a solution to the problem of tax shelter partnership …

Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten

Florida State University Law Review

No abstract provided.

Section 243 And Bootstrap Sales: The Dilemma Of The Corporate Shareholder, Don B. Cannada

Vanderbilt Law Review

The differences in the tax treatment of dividends and redemptions, the tax goals of individual and corporate shareholders, and the characterizations given corporate distributions by the Internal Revenue Service and the courts have combined to create over-whelming confusion for corporate bootstrap sales. The purpose of this Note is to formulate a rational, consistent approach to the tax treatment of corporate bootstrap sales. Accordingly, this Note initially will discuss various lines of cases governing the possible tax treatment of the seller in a bootstrap acquisition. Special emphasis will be placed on the recent line of cases that deny section 243 intercorporate …

Tightening The Limitations On Carryovers Under Section 382(B): F Reorganization And The Tax Reform Act Of 1976., J. Pat Tielborg

St. Mary's Law Journal

Abstract Forthcoming.

Loss-Leaders For The Inner Cities, Chester Smolski

Smolski Texts

"The Wall Street Journal has called it 'the latest war between the states.' It is a tool long used by Southern cities and states that only now is being utilized in the Northeast and Midwest. And it has been used by the city of Providence at the Biltmore Plaza.

Construing The Uniform Division Of Income For Tax Purposes Act: Reflections On The Illinois Supreme Courts Reading Of The "Throwback" Rule, Walter Hellerstein

Scholarly Works

Part I of this article examines the structure and underlying policy of the Uniform Division of income for Tax Purposes Act's provisions relating to the apportionment of income arising from economic activity conducted across state lines. In particular, it considers the Act's "throwback" rule, which reapportions income ordinarily apportioned to a state in which it is not taxable to one in which it is. Part II explores in detail the Illinois court's resolution of the problem raised by GTE, namely, how to assign sales of tangible personal property, which are used as a basis for apportioning income, when such sales …

Selected Practical Problems With Professional Associations And Professional Corporations., Robert Jorrie, Richard W. Wolf

St. Mary's Law Journal

Abstract Forthcoming.

Challenging The Tax Summons: Procedures And Defenses

William & Mary Law Review

No abstract provided.

Standing To Challenge Tax Treatment Of Competitors

William & Mary Law Review

No abstract provided.

An Approach To Income Tax Simplification, Fred W. Peel

University of Arkansas at Little Rock Law Review

No abstract provided.

Comment: The Federal Tax Consequences Of Life Insurance In Estate Planning, John B. Peace

University of Arkansas at Little Rock Law Review

No abstract provided.

Challenging The Determination Of Another Taxpayer's Status: The Effect Of Eastern Kentucky V. Welfare Rights Organization, Carla Lowenheim

North Carolina Central Law Review

No abstract provided.

Pre-Retirement Qualified Plan Pay-Outs Under Erisa, Harry V. Lamon, John W. Lee

Faculty Publications

No abstract provided.

Tax Avoidance, Alan Gunn

Michigan Law Review

This Article attempts an almost purely negative criticism. I contend that efforts to explain the results of tax cases not involving penalties by reference to "tax avoidance" are never satisfactory, whether the reference is meant to describe a taxpayer's state of mind or to justify a tax rule by invoking some "need to prevent tax avoidance." Because many tax problems are commonly discussed in terms of "tax avoidance" in one of these senses, and in order to avoid the impression that my arguments would leave the tax law in shambles, I shall suggest some alternative ways of dealing with these …

Carrybacks And The (F) Reorganization

William & Mary Law Review

No abstract provided.

Xi. Tax

Washington and Lee Law Review

No abstract provided.

Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture

William & Mary Law Review

No abstract provided.

Determination Of Fair Market Value For Ad Valorem Tax Purposes Of A Gas Lease Burdened With A Long-Term Sales Contract., Jack Lewis Iii

St. Mary's Law Journal

Abstract Forthcoming.

Recent Cases, Alan W. Duncan, Elton G. Snowden, William A. Holby, Joseph W. Gibbs

Vanderbilt Law Review

Constitutional Law -- Newsperson's Privilege - The First Amendment Guarantee of a Free Press Protects Against Compelled Disclosure of a Journalist's Exercise of Editorial Control and Judgment

Plaintiff, a former army officer who had achieved national prominence by claiming that his superiors ignored his reports of atrocities by American forces in Vietnam,' brought a libel suit against defendant television producer, reporter, and network for broadcasting a program that cast doubt upon plaintiff's allegations. Contending that defendant did not present available information corroborating plaintiff's claims, plaintiff sought discovery of the producer's beliefs, opinions, intent, and conclusions in preparing the program.

Alan …

Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola

Florida State University Law Review

No abstract provided.

Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten

Florida State University Law Review

Profit Sharing- NEW DEFINITION OF A PARTNERSHIP "PROFITS INTEREST" DISQUALIFIES AN OTHERWISE QUALIFIED PROFIT SHARING PLAN.

Discussion Draft Prepared For The Greater Hartford Chamber Of Commerce's Task Force On Tax Exempt Property, Richard Pomp

Faculty Articles and Papers

This Discussion Draft explains analyzes various approaches for municipalities to obtain revenue from tax-exempt property, and was prepared for the Hartford Chamber of Commerce’s Tax Force on Tax-Exempt Property.

It begins by examining the implementation of service charges, such as charges for various municipal services, in lieu of a traditional property tax. Because measuring actual consumption of services like fire and police are impractical, alternative approaches to approximate a user charge are explored.

The Discussion Draft then examines state payments to municipalities under a PILOT (payment in lieu of taxes) which Connecticut was using to offset municipal losses due to …

Material Participation And The Valuation Of Farm Land For Estate Tax Purposes Under The Tax Reform Act Of 1976, David A. Bratt

Kentucky Law Journal

No abstract provided.