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Articles 1 - 24 of 24
Full-Text Articles in Taxation-Federal
A Second Look At The Zero Basis Hoax, J. Clifton Fleming Jr.
A Second Look At The Zero Basis Hoax, J. Clifton Fleming Jr.
Faculty Scholarship
No abstract provided.
Recent Federal Income Tax Developments, Ira B. Shepard
Recent Federal Income Tax Developments, Ira B. Shepard
William & Mary Annual Tax Conference
No abstract provided.
Taxes, Morals, And Legitimacy, Leo P. Martinez
Designing A Hybrid Income-Consumption Tax, Michael S. Knoll
Designing A Hybrid Income-Consumption Tax, Michael S. Knoll
All Faculty Scholarship
No abstract provided.
What Part Of Rpos Don't You Understand? An Update And Survey Of Standards For Tax Return Positions, J. Timothy Philipps, Michael W. Mumbach, Morgan W. Alley
What Part Of Rpos Don't You Understand? An Update And Survey Of Standards For Tax Return Positions, J. Timothy Philipps, Michael W. Mumbach, Morgan W. Alley
Washington and Lee Law Review
No abstract provided.
West Virginia's Limited Liability Company Act: Problems With The Act, Ann Maxey
West Virginia's Limited Liability Company Act: Problems With The Act, Ann Maxey
West Virginia Law Review
No abstract provided.
The Politics Of The Income Tax, Joseph Bankman
The Politics Of The Income Tax, Joseph Bankman
Michigan Law Review
A Review of Dimensions of Law in the Service of Order: Origins of the Federal Income Tax by Robert Stanley
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 2), John W. Lee
Partnership Profits Share For Services: An Aggregate Exegesis Of Revenue Procedure 93-27 (Part 2), John W. Lee
Faculty Publications
In this article, Professor Lee charts two alternative methods for implementing an aggregate solution to the problem of partnership profits share for services. The functional, or judicial, method is to handle (1) the exchange of partner-capacity services for a profit share subject to the risk f the venture with the Culbertson "common law relation of partnership," nonrealization event doctrine, implicitly contemplated by the 1984 legislative history to section 707(a)(2), (2) the classic Diamond transitory partner with a substance-over-form rule or step-transaction rule, and (3) a sale of the partnership interest in circumstances that would result in ordinary income in a …
Determining An Individual's Federal Income Tax Liability When The Tax Benefit Rule Applies: A Fifty-Year Checkup Brings A New Prescription For Calculating Gross, Adjusted Gross, And Taxable Incomes, Matthew J. Barrett
BYU Law Review
No abstract provided.
Taxes, Morals, And Legitimacy, Leo P. Martinez
Taxes, Morals, And Legitimacy, Leo P. Martinez
Faculty Scholarship
No abstract provided.
The Summons Power And Tax Court Discovery: A Different Perspective, Leo P. Martinez
The Summons Power And Tax Court Discovery: A Different Perspective, Leo P. Martinez
Faculty Scholarship
No abstract provided.
The Paradox Of Corporate Giving: Tax Expenditures, The Nature Of The Corporation, And The Social Construction Of Charity, Nancy J. Knauer
The Paradox Of Corporate Giving: Tax Expenditures, The Nature Of The Corporation, And The Social Construction Of Charity, Nancy J. Knauer
Nancy J. Knauer
Corporate charitable giving is big business. Fundraisers estimate that in 1992, U.S. corporations contributed $6 billion to qualified charitable organizations. Hard-pressed for funds, qualified charities actively seek and compete for corporate contributions. Fundraising literature identifies corporate giving as the last great frontier of philanthropy. Marketing literature touts corporate giving as the latest advertising and public relations technique. Both camps proclaim that corporate giving is good for business and extol the business advantages which flow from transfers to charity. In short, corporate giving means doing best by doing good. Legal scholarship ignores the way corporate giving is described, justified, and expressed …
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel S. Goldberg
Tax Subsidies: One-Time Vs. Periodic An Economic Analysis Of The Tax Policy Alternatives, Daniel S. Goldberg
Faculty Scholarship
No abstract provided.
The Morality Of Money: American Attitudes Toward Wealth And The Income Tax, Marjorie E. Kornhauser
The Morality Of Money: American Attitudes Toward Wealth And The Income Tax, Marjorie E. Kornhauser
Indiana Law Journal
No abstract provided.
The Earned Income Tax Credit As A Tax Expenditure: An Alternative To Traditional Welfare Reform, Timothy J. Eifler
The Earned Income Tax Credit As A Tax Expenditure: An Alternative To Traditional Welfare Reform, Timothy J. Eifler
University of Richmond Law Review
Welfare has become a common topic of concern recently as President Clinton and his political adversaries begin battle over the second major element of Clinton's agenda for reform. As a necessary corollary to, and a direct complement of the health care proposal, the welfare system presents the next area that requires reform for a truly effective agenda for change.
Important Developments In Exempt Organizations, Stephen Schwarz, Laura B. Chisolm
Important Developments In Exempt Organizations, Stephen Schwarz, Laura B. Chisolm
Faculty Scholarship
No abstract provided.
The New Rollover Rules And Twenty Percent Withholding Tax On Pension Distributions: Does Good Pension Policy Favor Their Repeal?, Leandra Lederman
The New Rollover Rules And Twenty Percent Withholding Tax On Pension Distributions: Does Good Pension Policy Favor Their Repeal?, Leandra Lederman
Articles by Maurer Faculty
No abstract provided.
Below-Market Interest On Loans And Installment Sales: Tax Consequences, William T. Hutton
Below-Market Interest On Loans And Installment Sales: Tax Consequences, William T. Hutton
Faculty Scholarship
No abstract provided.
Graveyard Robbery In The Omnibus Budget Reconciliation Act Of 1993: A Modern Look At The Constitutionality Of Retroactive Taxes, 27 J. Marshall L. Rev. 775 (1994), Andrew G. Schultz
Graveyard Robbery In The Omnibus Budget Reconciliation Act Of 1993: A Modern Look At The Constitutionality Of Retroactive Taxes, 27 J. Marshall L. Rev. 775 (1994), Andrew G. Schultz
UIC Law Review
No abstract provided.
Redemptions Incident To Divorce: Reconciling Section 1041 And General Tax Principles, Leandra Lederman
Redemptions Incident To Divorce: Reconciling Section 1041 And General Tax Principles, Leandra Lederman
Articles by Maurer Faculty
No abstract provided.
Determining An Individual's Federal Income Tax Liability When The Tax Benefit Rule Applies: A Fifty-Year Checkup Brings A New Prescription For Calculating Gross, Adjusted Gross, And Taxable Incomes, Matthew J. Barrett
Journal Articles
The tax benefit rule should be described to indicate that it applies to credits and exclusions besides deductions, and deduction recoveries should be reported in the same location as was affected initially. The recovery should not affect gross income, for the purpose of tax equity. The recovery should rather affect either taxable income or adjusted gross income. The IRS and the courts should adopt this new description and principles.
Taxation Of Punitive Damages Obtained In A Personal Injury Claim, Douglas A. Kahn
Taxation Of Punitive Damages Obtained In A Personal Injury Claim, Douglas A. Kahn
Articles
The author explains that in recent court opinions and commentaries concerning whether punitive damages are taxable, considerable weight has been given to a negative inference that appears to lurk in a 1989 amendment to the relevant code provision, section 104(a)(2). To the contrary, he argues, the legislative history of that amendment and the form that the bill had when it was reported out of the Conference Committee establish beyond doubt that no such inference is warranted.
Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Federal Income Taxation, Cases And Materials, Hugh Ault, Paul Mcdaniel, Martin Mcmahon, Daniel Simmons
Hugh J. Ault
Supplemented by 1995 Supplement to Federal Income Taxation, Cases and Materials. 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1995; 1997 Supplement to Federal Income Taxation: Cases and Materials, 3rd ed., by McDaniel, Ault, McMahon and Simmons. Westbury, N.Y.: Foundation Press, 1997.
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault
Hugh J. Ault
No abstract provided.