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Taxation-Federal Commons

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1994

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Institution
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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. Dec 1994

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 Dec 1994

Recent Federal Income Tax Developments, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Taxes, Morals, And Legitimacy, Leo P. Martinez Sep 1994

Taxes, Morals, And Legitimacy, Leo P. Martinez

BYU Law Review

No abstract provided.


Designing A Hybrid Income-Consumption Tax, Michael S. Knoll Sep 1994

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 Sep 1994

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 Jun 1994

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 May 1994

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 Apr 1994

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 Mar 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Jan 1994

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 Dec 1993

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 Dec 1993

The Role Of Arbitration Procedures In Resolving Tax Disputes, Hugh Ault

Hugh J. Ault

No abstract provided.