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Articles 1 - 7 of 7
Full-Text Articles in Taxation-Federal
The U.S. Consumption Tax: Evolution, Not Revolution, Daniel Goldberg
The U.S. Consumption Tax: Evolution, Not Revolution, Daniel Goldberg
Daniel S. Goldberg
The article expresses the view that the current Internal Revenue Code has evolved into a hybrid income tax and consumption tax. It begins by explaining the difference between an income tax and a consumption tax and provides the backgrounds of the alternative forms of consumption tax: (1) consumed income, (2) yield exemption, and (3) point-of-sale taxation. Under the consumed income tax model of consumption tax, the individual taxpayer includes all items of income, both from labor and from capital, in its tax base, and then subtracts or deducts the portion of that income that he saves or invests. The resulting …
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel Goldberg
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel Goldberg
Daniel S. Goldberg
No abstract provided.
Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel Goldberg
Tax Planning For Interest After Tra 1984: Unstated Interest And Original Issue Discount, Daniel Goldberg
Daniel S. Goldberg
No abstract provided.
Effectively Representing Your Client Before The Irs, 5th Edition, T. Keith Fogg, Editor-In-Chief, T. Fogg
Effectively Representing Your Client Before The Irs, 5th Edition, T. Keith Fogg, Editor-In-Chief, T. Fogg
T. Keith Fogg
"Effectively Representing Your Client Before the IRS is a comprehensive collection of everything a tax professional should know when dealing with the IRS. Written by some of the most experienced tax controversy lawyers in the United States, it not only provides an in-depth discussion of the law, but is replete with realistic examples and hundreds of practice tips to aid tax practitioners during all stages of representation before the IRS in controversy matters, including exam, appeals, Tax Court, refund actions, and collection matters. The two-volume reference also includes a companion CD-ROM. No tax professional should be without Effectively Representing Your …
Tax Collection: Procedure And Strategies, T. Fogg
Relief For Taxpayers From The Federal Tax Lien, T. Fogg
Relief For Taxpayers From The Federal Tax Lien, T. Fogg
T. Keith Fogg
No abstract provided.
An "Outside Limit" For Refund Suits: The Case Against The Tax Exception To The Six-Year Bar On Claims Against The Government, Adam Gustafson
An "Outside Limit" For Refund Suits: The Case Against The Tax Exception To The Six-Year Bar On Claims Against The Government, Adam Gustafson
Adam R.F. Gustafson
Longstanding judicial precedent and the official position of the IRS agree that federal tax refund suits are limited only by the two-year statute of limitations of § 6532(a)(1) of the Internal Revenue Code, which is triggered only when the IRS mails the claimant a notice of disallowance. This Article contends that tax refund litigation is also governed by the six-year limitation of 28 U.S.C. § 2401(a) on “every civil action commenced against the United States,” which is triggered upon the accrual of a claim. The Supreme Court alluded to this dual-limitation scheme in 2008 in United States v. Clintwood Elkhorn …