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Articles 1 - 23 of 23
Full-Text Articles in Taxation-Federal
Recent Developments In Federal Income Taxation, Ira B. Shepard
Recent Developments In Federal Income Taxation, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Living With Passive Losses - A Practival Approach, Richard M. Lipton
Living With Passive Losses - A Practival Approach, Richard M. Lipton
William & Mary Annual Tax Conference
No abstract provided.
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, David H. Pogue, Richard E. Levine, Todd Wallace
Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, David H. Pogue, Richard E. Levine, Todd Wallace
William & Mary Annual Tax Conference
No abstract provided.
Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner
Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner
William & Mary Annual Tax Conference
No abstract provided.
Debt Discharge Income: Kirby Lumber Co. Revisited Under The "Transactional Equity" Rule Of Hillsboro, Louis A. Del Cotto
Debt Discharge Income: Kirby Lumber Co. Revisited Under The "Transactional Equity" Rule Of Hillsboro, Louis A. Del Cotto
Buffalo Law Review
No abstract provided.
An Argument For Current Deductability Of A Target's Expenses In A "Friendly" Takeover, Charles A. Lofaso
An Argument For Current Deductability Of A Target's Expenses In A "Friendly" Takeover, Charles A. Lofaso
Buffalo Law Review
No abstract provided.
Realization, Recognition, Reconciliation, Rationality And The Structure Of The Federal Income Tax System, Patricia D. White
Realization, Recognition, Reconciliation, Rationality And The Structure Of The Federal Income Tax System, Patricia D. White
Michigan Law Review
There are a few structural requirements that are necessarily common to any tax system. In Part I of this article I examine those requirements. I show that by isolating the necessary structure of a tax system from its particular content or goals, we can better understand the role played within the federal system of certain of its most characteristic features. In particular, I trace the function of the realization requirement for the recognition of income and distinguish it from another sort of function that could lead to the recognition of income within an income tax system. This second function is …
Davis V. Michigan And The Doctrine Of Retroactivity: States' Refund Liability For Taxation Of Federal Pension Income, Timothy B. Sherman
Davis V. Michigan And The Doctrine Of Retroactivity: States' Refund Liability For Taxation Of Federal Pension Income, Timothy B. Sherman
Brigham Young University Journal of Public Law
No abstract provided.
The Second Generation Of Notes Indexed For Inflation, Michael S. Knoll
The Second Generation Of Notes Indexed For Inflation, Michael S. Knoll
All Faculty Scholarship
No abstract provided.
The Innocent Spouse Problem: Joint And Several Liability For Income Taxes Should Be Repealed, Richard C.E. Beck
The Innocent Spouse Problem: Joint And Several Liability For Income Taxes Should Be Repealed, Richard C.E. Beck
Vanderbilt Law Review
Husbands and wives who elect to file joint federal income tax returns are jointly and severally liable for the entire tax due. Ninety-nine percent of married couples who file income tax returns make the election to file jointly, and each spouse thereby incurs personal liability for the other spouse's income taxes.' This Article argues that the rule is unfair and unjustified and should be repealed.
Part II of the Article describes the nature and scope of the problems caused by joint and several liability of spouses filing joint re-turns (hereinafter "joint return liability"). When separation or divorce is involved, the …
Federal Taxation Of Prepaid College Tuition Plans, J. Timothy Philipps
Federal Taxation Of Prepaid College Tuition Plans, J. Timothy Philipps
Washington and Lee Law Review
No abstract provided.
Tax Deductions For Payments To Mormon Missionaries, K. C. Jensen
Tax Deductions For Payments To Mormon Missionaries, K. C. Jensen
Brigham Young University Journal of Public Law
No abstract provided.
Jurisdiction Over Civil Tax Cases, Larry Kramer
Important Developments In Exempt Organizations, Stephen Schwarz, Miriam Galston
Important Developments In Exempt Organizations, Stephen Schwarz, Miriam Galston
Faculty Scholarship
No abstract provided.
The Innocent Spouse Problem: Joint And Several Liability For Income Taxes Should Be Repealed., Richard C.E. Beck
The Innocent Spouse Problem: Joint And Several Liability For Income Taxes Should Be Repealed., Richard C.E. Beck
Articles & Chapters
Husbands and wives who elect to file joint federal income tax returns
are jointly and severally liable for the entire tax due. Ninety-nine
percent of married couples who file income tax returns make the election
to file jointly, and each spouse thereby incurs personal liability for
the other spouse's income taxes. This Article argues that the rule is
unfair and unjustified and should be repealed
Electronic Tax Returns And The Preparer Penalties, 10 Computer L.J. 551 (1990), Michael W. Traynham
Electronic Tax Returns And The Preparer Penalties, 10 Computer L.J. 551 (1990), Michael W. Traynham
UIC John Marshall Journal of Information Technology & Privacy Law
No abstract provided.
Mathematical Prescriptions For Relief Of The Public Charity Status Blues, William T. Hutton
Mathematical Prescriptions For Relief Of The Public Charity Status Blues, William T. Hutton
Faculty Scholarship
No abstract provided.
Spin-Offs Before And After The Tax Reform Act, Donald F. Brosnan
Spin-Offs Before And After The Tax Reform Act, Donald F. Brosnan
Buffalo Law Review
No abstract provided.
Federal Income Taxation And Community Property Law: The Case For Divorce, John A. Miller
Federal Income Taxation And Community Property Law: The Case For Divorce, John A. Miller
Articles
No abstract provided.
The Two Faces Of Tax Neutrality: Do They Interact Or Are They Mutually Exclusive?, Douglas A. Kahn
The Two Faces Of Tax Neutrality: Do They Interact Or Are They Mutually Exclusive?, Douglas A. Kahn
Articles
The term "tax neutrality" refers to at least two quite different concepts. In its most common usage, tax neutrality refers to tax provisions that conform to an ideal tax system. A tax provision that is consistent with such an ideal system is described as "neutral." A tax provision that cannot be reconciled with the ideal system is sometimes referred to as a "tax expenditure" item. I will discuss tax expenditures later in this paper.
Beyond The Fruit Tree: A Proposal For Revision Of The Assignment Of Income Doctrine—Caruth Corp. V. United States, 865 F.2d 644 (5th Cir. 1989), Traci A. Sammeth
Beyond The Fruit Tree: A Proposal For Revision Of The Assignment Of Income Doctrine—Caruth Corp. V. United States, 865 F.2d 644 (5th Cir. 1989), Traci A. Sammeth
Washington Law Review
The Supreme Court developed the assignment of income doctrine to solve the question of who the proper taxpayer is under section 61 of the Internal Revenue Code. The question arises when individuals transfer income that rightly belongs to them without declaring the income for federal tax purposes. The assignment doctrine attributes income, for tax purposes, to the earner or practical owner of the income notwithstanding that person's assignment of the income. However, the Supreme Court's development of the doctrine has been inadequate, as exemplified by the recent decision of the Fifth Circuit Court of Appeals in Caruth Corp. v. United …
Taxing International Income: An Analysis Of The U.S. System And Its Economic Premises, Hugh Ault, David Bradford
Taxing International Income: An Analysis Of The U.S. System And Its Economic Premises, Hugh Ault, David Bradford
Hugh J. Ault
No abstract provided.
Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation Of Partnerships And S Corporations, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1991 Supplement to Federal Income Taxation of Partnerships and S Corporations, by McDaniel, Ault, McMahon, and Simmons. Westbury, N.Y.: Foundation Press, 1991; 1992 Supplement to Federal Income Taxation of Partnerships and S Corporations, by McDaniel, Ault, McMahon, and Simmons. Westbury, N.Y.: Foundation Press, 1992.