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817 full-text articles. Page 1 of 17.

Front Matter (Letter From The Editor, Masthead, Etc.), 2021 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


The Tax Implications Of The American Families Plan On Iowa Farmland Owners, Kristine Tidgren, Wendong Zhang 2021 Iowa State University

The Tax Implications Of The American Families Plan On Iowa Farmland Owners, Kristine Tidgren, Wendong Zhang

CARD Policy Briefs

President Biden proposed the American Families Plan (AFP) on April 28, 2021, to provide new social programs to millions of Americans. To pay for this $1.8 trillion benefits package, the AFP proposes significantly changing the way capital gain is taxed. The Administration has explained that “reforms to the taxation of capital gains and qualified dividends will reduce economic disparities among Americans and raise needed revenue.” Specifically, the AFP proposes increasing the top marginal tax rate, taxing some capital gain at ordinary income tax rates, and subjecting more gain to the 3.8% Medicare tax. The AFP would thus boost ...


Chadwick V. Comm’R, Jerica Barber 2021 Golden Gate University School of Law

Chadwick V. Comm’R, Jerica Barber

GGU Tax & Estate Planning Review

Nature of Case: Whether written supervisor approval is required for trust fund recovery penalties to be collected against a responsible person required to submit employment taxes when penalties assessment recommendation forms were submitted by IRS revenue officers?


Ruesch V. Comm’R, Alexis Pickins 2021 Golden Gate University School of Law

Ruesch V. Comm’R, Alexis Pickins

GGU Tax & Estate Planning Review

Nature of Case: Whether the U.S. Tax Court has jurisdiction to decide Ms. Ruesch’s underlying liability for penalties assessed by the Internal Revenue Services (IRS); and whether Ms. Ruesch’s claim against the IRS is moot due to the IRS’s reversal of their classification of her as seriously delinquent?

The two important issues at dispute are: (1) whether the U.S. Tax Court has jurisdiction to decide Ms. Ruesch’s underlying liability for penalties assessed by the Internal Revenue Services (IRS); and (2) whether Ms. Ruesch’s claim against the IRS is moot due to the IRS ...


Using Tax Law To Perpetuate Gentrification: Vinegar Hill Lives Again In Charlottesville, Kelsey Massey 2021 Golden Gate University School of Law

Using Tax Law To Perpetuate Gentrification: Vinegar Hill Lives Again In Charlottesville, Kelsey Massey

GGU Tax & Estate Planning Review

The 2017 Tax Cuts and Jobs Act, enacted by the Trump administration, created the largest government-sponsored subsidy for urban renewal through the Opportunity Zones program. This tax expenditure is designed to delay and even avoid capital gains taxes to incentivize development in areas deemed to be in economic distress. While the program’s stated intent is to revitalize neighborhoods, build affordable housing, or promote small businesses, the selection of qualified areas is based on the income rate of residents. That is to say, a subsidy program focused on the physical place improvements has based its designation criteria on local resident ...


Table Of Contents, Seattle University Law Review 2021 Seattle University School of Law

Table Of Contents, Seattle University Law Review

Seattle University Law Review

Table of Contents


Why A Federal Wealth Tax Is Constitutional, Ari Glogower, David Gamage, Kitty Richards 2021 The Ohio State University

Why A Federal Wealth Tax Is Constitutional, Ari Glogower, David Gamage, Kitty Richards

Articles by Maurer Faculty

The 2020 Democratic presidential primaries brought national attention to a new direction for the tax system: a federal wealth tax for the wealthiest taxpayers. During their campaigns, Senators Elizabeth Warren (D-MA) and Bernie Sanders (I-VT) both introduced proposals to tax the wealth of multimillionaires and billionaires, and to use the revenue for public investments, including in health care and education. These reforms generated broad public support—even among many Republicans—and broadened the conversation over the future of progressive tax reform.

A well-designed, high-end wealth tax can level the playing field in an unequal society and promote shared economic prosperity ...


Interview: Robert Patterson, Bacilio Mendez 2020 Golden Gate University School of Law

Interview: Robert Patterson, Bacilio Mendez

GGU Tax & Estate Planning Review

Dr. Marcia Ruben, Assistant Professor and Chair of GGU’s Graduate Management Program, speaks with Robert Patterson—an MS Taxation alumnus and Director and Worldwide Tax & Trade Controller at Microsoft—about his life and career.


The Rich, Lucas A. Santos 2020 Kutztown University

The Rich, Lucas A. Santos

English Department: Research for Change - Wicked Problems in Our World

The rise of the super rich dramatically rose in the 1980’s. The once dominant oil and gas sector was taken over by finance and technology overall. We are able to see a rise of these super rich, or the one percent, and even how quickly they were able to recover from the 2008 Recession. Now, the one percent are making continuous substantial gains in a current world, where a pandemic has struck and many are struggling. I talk about the use of public policy in order to regain this economic gap between the one percent and the rest of ...


Enough Is As Good As A Feast, Noah C. Chauvin 2020 Seattle University School of Law

Enough Is As Good As A Feast, Noah C. Chauvin

Seattle University Law Review

Ipse Dixit, the podcast on legal scholarship, provides a valuable service to the legal community and particularly to the legal academy. The podcast’s hosts skillfully interview guests about their legal and law-related scholarship, helping those guests communicate their ideas clearly and concisely. In this review essay, I argue that Ipse Dixit has made a major contribution to legal scholarship by demonstrating in its interview episodes that law review articles are neither the only nor the best way of communicating scholarly ideas. This contribution should be considered “scholarship,” because one of the primary goals of scholarship is to communicate new ...


Interview: Nathan Pastor On Barefoot V. Jennings, Bacilio Mendez II 2020 Golden Gate University School of Law

Interview: Nathan Pastor On Barefoot V. Jennings, Bacilio Mendez Ii

GGU Tax & Estate Planning Review

In February 2020 (read: pre-COVID-19-pandemic and the California shelter-in-place order taking hold), I was lucky enough to sit down with Nathan Pastor (JD ’14, LLM ’16, right) to discuss a case that resulted in a seismic shift in California probate law—Barefoot v. Jennings.


Mandatory Tax Penalty Insurance, Michael Abramowicz 2020 George Washington University Law School

Mandatory Tax Penalty Insurance, Michael Abramowicz

Indiana Law Journal

In a mandatory tax penalty insurance regime, taxpayers would be required to find insurers to certify portions of their tax returns. A certifying insurer would be subject to a governmental auditing regime insurers of randomly selected filings would pay an amount equal to the inverse of the selection probability multiplied by the underpayment, or they would receive money from the government in the case of overpayment. The insurers function as private auditors with no incentive to underestimate their customers' tax liability. Such a regime will consume real resources, ultimately paid by taxpayers, and thus should not be imposed universally. But ...


Table Of Contents, Seattle University Law Review 2020 Seattle University School of Law

Table Of Contents, Seattle University Law Review

Seattle University Law Review

Table of Contents


Front Matter (Letter From The Editor, Masthead, Etc.), 2020 San Jose State University

Front Matter (Letter From The Editor, Masthead, Etc.)

The Contemporary Tax Journal

No abstract provided.


In Re. Estate Of Easterday, Corey Michelle Timpson 2020 Golden Gate University School of Law

In Re. Estate Of Easterday, Corey Michelle Timpson

GGU Tax & Estate Planning Review

Whether pending divorce has an effect on entitlement to life insurance; and whether ERISA preempts state law specifically relating to enforcement of a contractual waiver in relation to pension benefits.


Reforming State Corporate Income Taxes Can Yield Billions, Darien Shanske, Reuven S. Avi-Yonah, David Gamage 2020 University of California, Davis

Reforming State Corporate Income Taxes Can Yield Billions, Darien Shanske, Reuven S. Avi-Yonah, David Gamage

Articles by Maurer Faculty

The federal government should be providing states and localities with hundreds of billions of dollars in aid. The arguments against such aid, including the claim that the states have somehow been profligate, do not stand up to scrutiny. Nevertheless, it seems unlikely that the federal government will do enough, and it is already the case that the federal government is acting too slowly. States and local governments, which generally operate under balanced budget constraints, are, accordingly, already making sweeping cuts4 that will deepen the recession and reduce services when they are most needed.

Rather than make these cuts, it would ...


Sveen V. Melin, Steven J. Reading 2020 Golden Gate University School of Law

Sveen V. Melin, Steven J. Reading

GGU Tax & Estate Planning Review

Does the retroactive application of a revocation-on-divorce statute to contracts entered into prior to the enactment of the statute violate the Contracts Clause of the Constitution?


Dieringer V.Comm'r Of Internal Revenue, Christian Ramos 2020 Golden Gate University School of Law

Dieringer V.Comm'r Of Internal Revenue, Christian Ramos

GGU Tax & Estate Planning Review

Whether the Tax Court 1) should have valued the charitable gift at Victoria’s Date of Death, 2) even if post-death events could be considered, the Tax Court erred by not accounting for a decline in value of Victoria’s shares caused by economic forces, and 3) the Tax Court erred by upholding the accuracy-related penalty under I.R.C. § 662.


In Re. Sealed Case, Christian Ramos 2020 Golden Gate University School of Law

In Re. Sealed Case, Christian Ramos

GGU Tax & Estate Planning Review

Whether the Tax Court abused its discretion in denying the Appellant’s request to proceed anonymously because he is a serial filer who relies upon public information


N.C. Dep’T Of Revenue V. Kimberley Rice Kaestner 1992 Family Trust, Corey Michelle Timpson 2020 Golden Gate University School of Law

N.C. Dep’T Of Revenue V. Kimberley Rice Kaestner 1992 Family Trust, Corey Michelle Timpson

GGU Tax & Estate Planning Review

Whether a State can tax a trust income for the benefit of a North Carolina resident when no income was, or could have been, received by the trust and when no connection to the Trust existed outside of the beneficiary’s residence in North Carolina.


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