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Articles 1 - 24 of 24
Full-Text Articles in Taxation-Federal
Is The Biggest Offer The Best Offer?, Alyssa Croft
Is The Biggest Offer The Best Offer?, Alyssa Croft
Pace Intellectual Property, Sports & Entertainment Law Forum
Many people strive to be professional athletes because of the respect and accomplishment it receives. You make a lot of money, it can be glamorous, you are in commercials and magazines, and sometimes even movies. However, there are some things people do not think about when it comes to professional athletes. One of the biggest is taxation! There are so many different things athletes must think about and do because of taxes so they can take home the most amount of money possible. Athletes must be careful about who they hire to help them with their taxes because they want …
Taxing Combat, Samuel Kan
Taxing Combat, Samuel Kan
Dickinson Law Review (2017-Present)
When you are being shot at or dodging landmines you are in a combat zone. Diplomatic niceties aside, these brave warriors are in danger because of the policies of their Government and we must take care of them. Quite frankly, we must act to insure that we do not have a repeat of what happened in Somalia. In Somalia, the families of the soldiers who lost their lives could not receive the benefits that should have gone to them under the Tax Code because the President never declared it a combat zone.
We don’t know exactly where we’re at in …
How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber
How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber
Journal of Law and Policy
The ratification of the Sixteenth Amendment to the United States Constitution granted Congress the right to tax income “from whatever source derived.” Since its inception, the tax code has become long and complicated, filled with broad taxation rules and innumerable exceptions. Over time, the tax code has been amended with the stated purpose of promoting “fairness, efficiency, and enforceability.” However, the complexity of the tax code has led to abuse of “tax loopholes” by wealthy taxpayers who want to avoid paying their fair share of taxes. While abuse is likely to continue, as legislators remain intent on lowering taxes on …
How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber
How The 1 Percent Pays Taxes; How The 99 Percent Could: The Subchapter T Worker Cooperative Tax Loophole, Michael Haber
Journal of Law and Policy
The ratification of the Sixteenth Amendment to the United States Constitution granted Congress the right to tax income “from whatever source derived.” Since its inception, the tax code has become long and complicated, filled with broad taxation rules and innumerable exceptions. Over time, the tax code has been amended with the stated purpose of promoting “fairness, efficiency, and enforceability.” However, the complexity of the tax code has led to abuse of “tax loopholes” by wealthy taxpayers who want to avoid paying their fair share of taxes. While abuse is likely to continue, as legislators remain intent on lowering taxes on …
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Income Tax - Deductions For Facilitating Payments To Foreign Government Officials, Birney Bull
Georgia Journal of International & Comparative Law
No abstract provided.
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Moving Beyond Marriage: A Proposed Unit Of Presumed Economic Interdependence For Joint Filing Purposes In Bankruptcy And In Tax, Heather V. Graham
Pace Law Review
In order to promote both equality and efficiency, this Comment proposes that individuals should have the opportunity to file jointly for tax and bankruptcy purposes when they have a relationship predicated upon economic interdependence, as opposed to basing the opportunity to file jointly upon marital status. Part I of this Comment will briefly discuss the history of marriage in the United States. In particular, Part I will discuss the role that the government has had in promoting and regulating marriage and how the treatment of married persons operates to the exclusion of the unmarried. Parts II and III of this …
The Individual Mandate Tax Penalty, Jeffrey H. Kahn
The Individual Mandate Tax Penalty, Jeffrey H. Kahn
Scholarly Publications
In 2010, President Obama signed legislation that significantly altered the healthcare and health insurance markets in the United States. An integral part of that reform is the individual mandate, a provision that requires individuals to purchase and maintain healthcare insurance. Failure to maintain such coverage subjects an individual to a tax penalty. The Supreme Court upheld the constitutionality of that provision under Congress’s taxing power.
Despite the Supreme Court upholding the individual mandate, fundamental questions remain. This Article addresses the question of whether the use of a tax penalty to encourage taxpayers to do something that the government desires is …
Financial Disability For All, T. Keith Fogg, Rachel E. Zuraw
Financial Disability For All, T. Keith Fogg, Rachel E. Zuraw
Catholic University Law Review
No abstract provided.
Free Rider: A Justification For Mandatory Medical Insurance Under Health Care Reform?, Jeffrey H. Kahn, Douglas A. Kahn
Free Rider: A Justification For Mandatory Medical Insurance Under Health Care Reform?, Jeffrey H. Kahn, Douglas A. Kahn
Scholarly Publications
Section 1501 of the Patient Protection and Affordable Care Act added section 5000A to the Internal Revenue Code to require most individuals in the United States, beginning in the year 2014, to purchase an established minimum level of medical insurance. This requirement, which is enforced by a penalty imposed on those who fail to comply, is sometimes referred to as the “individual mandate.” The individual mandate is one element of a vast change to the provision of medical care that Congress implemented in 2010. The individual mandate has proved to be controversial and has been the subject of a number …
Prevention Of Double Deductions Of A Single Loss: Solutions In Search Of A Problem, Jeffrey H. Kahn, Douglas A. Kahn
Prevention Of Double Deductions Of A Single Loss: Solutions In Search Of A Problem, Jeffrey H. Kahn, Douglas A. Kahn
Scholarly Publications
No abstract provided.
Secondary Liability For Federal Trust Fund Taxes, Steve R. Johnson
Secondary Liability For Federal Trust Fund Taxes, Steve R. Johnson
Scholarly Publications
When collection of unpaid taxes cannot be effected from the person primarily liable for them, the Internal Revenue Code creates for the IRS a number of mechanisms for collection from secondary parties. To satisfy the requirements of fairness and due process, secondary liability is imposed only when the party has some nexus to the liability, that is, when that person's actions helped create the liability or frustrated its collection from the primary taxpayer.
This article discusses l.R.C. § 6672, one of the most widely used and important of the secondary liability mechanisms in tax. There are numerous § 6672 assessments …
Federal Tax Collection Controversies In The Era Of Drye, Steve R. Johnson
Federal Tax Collection Controversies In The Era Of Drye, Steve R. Johnson
Scholarly Publications
By “tax collection controversies,” I mean cases in which it has been established that the taxpayer owes additional taxes, those taxes remain unpaid, and the IRS is attempting to enforce collection out of the taxpayer’s assets. Such cases are numerous and involve attorneys in general legal practice as well as tax specialists. For example, the taxpayer may be your client for non-tax matters, and may expect you to handle her tax collection controversy as well. Or, your client may not be the taxpayer herself, but instead someone who co-owns property with the taxpayer. Your client expects you to make sure …
Rendering Unto Caesar Or Electioneering For Caesar--Loss Of Church Tax Exemption For Participation In Electoral Politics, Alan L. Feld
Rendering Unto Caesar Or Electioneering For Caesar--Loss Of Church Tax Exemption For Participation In Electoral Politics, Alan L. Feld
Faculty Scholarship
The restriction on church participation in political campaigns contained in the Internal Revenue Code operates uneasily. It appears to serve the useful purpose of separating the spheres of religion and electoral politics. But the separation often is only apparent, as churches in practice signal support for a particular candidate in a variety of rays that historically have not cost them their exemptions. Although the limited enforcement by the Internal Revenue Service has reflected the sensitive nature of the First Amendment values present, the federal government should provide more formal elaboration by statute or regulation. Focus on the use of funds …
Reflections On Executive Compensation And A Modest Proposal For (Further) Reform, Mark J. Loewenstein
Reflections On Executive Compensation And A Modest Proposal For (Further) Reform, Mark J. Loewenstein
Publications
No abstract provided.
The Limited Liability Company Experiment: Unlimited Flexibility, Uncertain Role, Wayne M. Gazur
The Limited Liability Company Experiment: Unlimited Flexibility, Uncertain Role, Wayne M. Gazur
Publications
No abstract provided.
Of No Interest: Truth, Substance, And Bargain Borrowing, Joseph W. Jacobs
Of No Interest: Truth, Substance, And Bargain Borrowing, Joseph W. Jacobs
Florida State University Law Review
No abstract provided.
The Continuing Saga Of Prepaid Feed Expense: The Fat Lady Has Not Sung, James D. Wright, Nancy E. Wright
The Continuing Saga Of Prepaid Feed Expense: The Fat Lady Has Not Sung, James D. Wright, Nancy E. Wright
Florida State University Law Review
No abstract provided.
Section 302(C)(2): Opportunities And Pitfalls, Michael A. Jones
Section 302(C)(2): Opportunities And Pitfalls, Michael A. Jones
Florida State University Law Review
No abstract provided.
Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr.
Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr.
Florida State University Law Review
No abstract provided.
Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.
Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.
Florida State University Law Review
No abstract provided.
Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten
Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten
Florida State University Law Review
No abstract provided.
Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola
Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola
Florida State University Law Review
No abstract provided.
Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten
Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten
Florida State University Law Review
Profit Sharing- NEW DEFINITION OF A PARTNERSHIP "PROFITS INTEREST" DISQUALIFIES AN OTHERWISE QUALIFIED PROFIT SHARING PLAN.
The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.
The Tax Consequences Of Inter Vivos Charitable Contributions After December 31, 1969 Under Section 170, Olin R. Melchionna Jr.
University of Richmond Law Review
To give and live to give again has always been the American way. Traditionally, Americans contribute to those charitable institutions and associations which effectuate their benevolent, philanthropic desires. Many individuals believe the funding of charitable institutions should be primarily by direct contributions from the private sector as opposed to federal and state government subsidies. This view is supported by the federal income, I gift and estate tax deductions.