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Taxation-Federal Commons

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1990

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Institution
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Articles 1 - 23 of 23

Full-Text Articles in Taxation-Federal

Recent Developments In Federal Income Taxation, Ira B. Shepard Dec 1990

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 Dec 1990

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 Dec 1990

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 Nov 1990

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 Oct 1990

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 Oct 1990

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 Jun 1990

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 May 1990

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 Apr 1990

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 Mar 1990

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 Mar 1990

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 Mar 1990

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 Mar 1990

Jurisdiction Over Civil Tax Cases, Larry Kramer

BYU Law Review

No abstract provided.


Important Developments In Exempt Organizations, Stephen Schwarz, Miriam Galston Jan 1990

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 Jan 1990

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 Jan 1990

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 Jan 1990

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 Jan 1990

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 Jan 1990

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 Jan 1990

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 Jan 1990

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 Dec 1989

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 Dec 1989

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.