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Full-Text Articles in Taxation-Federal
An Introduction To Capital Gain And Losses, Roland L. Hjorth
An Introduction To Capital Gain And Losses, Roland L. Hjorth
Washington Law Review
In this article, originally prepared for his class in federal income tax, Professor Hjorth explores the theoretical bases and working principles underlying the taxation of capital gains and losses. Beginning with a review of basic federal income tax concepts and the provisions governing computation and recognition of all gains and losses, he proceeds through a comprehensive discussion of the basic Code provisions governing capital gains and losses. Additional discussion focuses on the specialized treatment afforded quasi-capital assets, copyrights and patents, inventory, discount bonds, short sales, small business stock, and foreign corporations.
Exemptions For Dependents: The Burden Of Proof Dilemma For Divorced Or Separated Parents, Anon
Exemptions For Dependents: The Burden Of Proof Dilemma For Divorced Or Separated Parents, Anon
Washington Law Review
Plaintiff, divorced and living apart from his former wife who had custody of their two sons, claimed dependency exemptions for both sons in his federal income tax returns for the two years in question. The Commissioner of Internal Revenue disallowed the exemption for one son in each of the two years. In affirming the Commissioner's determination, the Tax Court held that plaintiff failed to sustain the burden of proving that his contribution was more than half the total support of the children. Though able to establish the amount of his contribution, plaintiff could not prove the amount of support from …
Taxation Of Corporate Stock Received By Sole Shareholders Upon Cancellation Of Salary Obligations, Anon
Taxation Of Corporate Stock Received By Sole Shareholders Upon Cancellation Of Salary Obligations, Anon
Washington Law Review
Randall and Fender, sole and equal shareholders of Fender Sales, Inc., twice cancelled equal salary debts owned to them by their corporation. As part of these transactions, the corporation issued $100 par value common stock for each $100 of salary debt owed. Neither the corporation, which had previously deducted the salary liabilities as expenses for federal income tax purposes, nor the individuals, who were cash basis taxpayers, reported any income as a result of these transactions. The Commissioner of Internal Revenue determined that the receipt of stock constituted taxable salary income to the individuals or, alternatively, that the cancellation resulted …
Federal Income Tax Liability—Exception To Marital Bankruptcy, Anon
Federal Income Tax Liability—Exception To Marital Bankruptcy, Anon
Washington Law Review
Mrs. Draper had incurred unpaid federal income tax obligations prior to her marriage to Delmar Draper, and the Internal Revenue Service levied on one-half of Mrs. Draper's wages during marriage. The Drapers brought suit as a marital community to quiet title to the salary levied on to satisfy the wife's premarital obligation, contending that the wife's wages were community property and, therefore, not subject to satisfaction for the premarital debt. Defendant's motion to dismiss was sustained. Held: One-half of a spouse's wages, even though community property, can be levied on to satisfy a premarital federal income tax liability. Draper v. …
Loss Carryovers Under The 1954 Code: Rejection Of The Libson Shops Doctrine, Anon
Loss Carryovers Under The 1954 Code: Rejection Of The Libson Shops Doctrine, Anon
Washington Law Review
Taxpayer corporation, which had sustained losses in the hardware business, entered into an agreement with two partners engaged in real estate development whereby a department of real estate development was established within the corporation. Funds needed for the department's operations were furnished by the partners through the purchase of non-voting preferred stock valued at approximately two-fifths of the total value of the corporate stock. By the terms of the agreement, ninety percent of the profits of the department were to be distributed to the preferred stockholders. Voting control of the common stock was placed in a voting trust. Thereafter, the …