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Full-Text Articles in Taxation-Federal
The Capital Nature Of Educational Expenses, Anon
The Capital Nature Of Educational Expenses, Anon
Washington Law Review
Taxpayer, a practicing psychiatrist and part-time teacher of psychiatry, undertook a six year training program in psychoanalysis at the Boston Psychoanalytic Institute. In 1961, he deducted $3,650 paid in fees to the Institute as a business expense under section 162 of the Internal Revenue Code. Although taxpayer contended that the expenses were incurred primarily to maintain or improve skills required in his profession, the Commissioner disallowed the deduction. A sharply divided Tax Court upheld the disallowance, relying on two prior cases holding that when a psychiatrist undertakes training in psychoanalysis, he manifests an intent to acquire a specialty, not to …
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Washington Law Review
Liquidations and reincorporations have been utilized in attempts to bail out corporate earnings and profits at capital gains rates. The success of these attempts has been limited by judicial extension of the corporate reorganization sections of the Internal Revenue Code. Professor Hjorth suggests that specific Congressional amendment of section 331 to encompass the liquidation reincorporation problem is preferable to extension of the reorganization provisions which occurred in the recent case of Davant v. Commissioner.
The Capital Nature Of Educational Expenses, Anon
The Capital Nature Of Educational Expenses, Anon
Washington Law Review
Taxpayer, a practicing psychiatrist and part-time teacher of psychiatry, undertook a six year training program in psychoanalysis at the Boston Psychoanalytic Institute. In 1961, he deducted $3,650 paid in fees to the Institute as a business expense under section 162 of the Internal Revenue Code. Although taxpayer contended that the expenses were incurred primarily to maintain or improve skills required in his profession, the Commissioner disallowed the deduction. A sharply divided Tax Court upheld the disallowance, relying on two prior cases holding that when a psychiatrist undertakes training in psychoanalysis, he manifests an intent to acquire a specialty, not to …
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Washington Law Review
Liquidations and reincorporations have been utilized in attempts to bail out corporate earnings and profits at capital gains rates. The success of these attempts has been limited by judicial extension of the corporate reorganization sections of the Internal Revenue Code. Professor Hjorth suggests that specific Congressional amendment of section 331 to encompass the liquidation reincorporation problem is preferable to extension of the reorganization provisions which occurred in the recent case of Davant v. Commissioner.