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Articles 1 - 29 of 29
Full-Text Articles in Law
Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles
Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles
Vanderbilt Law Review
This Note first will set forth the Treasury Department's perception of the present abuses of tax shelter partnerships and will analyze existing procedural rules, the Treasury Department's proposed amendments, and the House of Representatives' proposed amendments in light of these abuses. Next, the Note will examine the substantive law of Subchapter K and will attempt to point out the probable effects of the proposed amendments on the aggregate concept of partnerships, on substantive partnership tax law, and on the viability of the partnership form of business. Finally, this Note will propose a solution to the problem of tax shelter partnership …
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.
Section 243 And Bootstrap Sales: The Dilemma Of The Corporate Shareholder, Don B. Cannada
Section 243 And Bootstrap Sales: The Dilemma Of The Corporate Shareholder, Don B. Cannada
Vanderbilt Law Review
The differences in the tax treatment of dividends and redemptions, the tax goals of individual and corporate shareholders, and the characterizations given corporate distributions by the Internal Revenue Service and the courts have combined to create over-whelming confusion for corporate bootstrap sales. The purpose of this Note is to formulate a rational, consistent approach to the tax treatment of corporate bootstrap sales. Accordingly, this Note initially will discuss various lines of cases governing the possible tax treatment of the seller in a bootstrap acquisition. Special emphasis will be placed on the recent line of cases that deny section 243 intercorporate …
Tightening The Limitations On Carryovers Under Section 382(B): F Reorganization And The Tax Reform Act Of 1976., J. Pat Tielborg
Tightening The Limitations On Carryovers Under Section 382(B): F Reorganization And The Tax Reform Act Of 1976., J. Pat Tielborg
St. Mary's Law Journal
Abstract Forthcoming.
Selected Practical Problems With Professional Associations And Professional Corporations., Robert Jorrie, Richard W. Wolf
Selected Practical Problems With Professional Associations And Professional Corporations., Robert Jorrie, Richard W. Wolf
St. Mary's Law Journal
Abstract Forthcoming.
Challenging The Tax Summons: Procedures And Defenses
Challenging The Tax Summons: Procedures And Defenses
William & Mary Law Review
No abstract provided.
Standing To Challenge Tax Treatment Of Competitors
Standing To Challenge Tax Treatment Of Competitors
William & Mary Law Review
No abstract provided.
Comment: The Federal Tax Consequences Of Life Insurance In Estate Planning, John B. Peace
Comment: The Federal Tax Consequences Of Life Insurance In Estate Planning, John B. Peace
University of Arkansas at Little Rock Law Review
No abstract provided.
Challenging The Determination Of Another Taxpayer's Status: The Effect Of Eastern Kentucky V. Welfare Rights Organization, Carla Lowenheim
Challenging The Determination Of Another Taxpayer's Status: The Effect Of Eastern Kentucky V. Welfare Rights Organization, Carla Lowenheim
North Carolina Central Law Review
No abstract provided.
An Approach To Income Tax Simplification, Fred W. Peel
An Approach To Income Tax Simplification, Fred W. Peel
University of Arkansas at Little Rock Law Review
No abstract provided.
Tax Avoidance, Alan Gunn
Tax Avoidance, Alan Gunn
Michigan Law Review
This Article attempts an almost purely negative criticism. I contend that efforts to explain the results of tax cases not involving penalties by reference to "tax avoidance" are never satisfactory, whether the reference is meant to describe a taxpayer's state of mind or to justify a tax rule by invoking some "need to prevent tax avoidance." Because many tax problems are commonly discussed in terms of "tax avoidance" in one of these senses, and in order to avoid the impression that my arguments would leave the tax law in shambles, I shall suggest some alternative ways of dealing with these …
Carrybacks And The (F) Reorganization
Recent Cases, Alan W. Duncan, Elton G. Snowden, William A. Holby, Joseph W. Gibbs
Recent Cases, Alan W. Duncan, Elton G. Snowden, William A. Holby, Joseph W. Gibbs
Vanderbilt Law Review
Constitutional Law -- Newsperson's Privilege - The First Amendment Guarantee of a Free Press Protects Against Compelled Disclosure of a Journalist's Exercise of Editorial Control and Judgment
Plaintiff, a former army officer who had achieved national prominence by claiming that his superiors ignored his reports of atrocities by American forces in Vietnam,' brought a libel suit against defendant television producer, reporter, and network for broadcasting a program that cast doubt upon plaintiff's allegations. Contending that defendant did not present available information corroborating plaintiff's claims, plaintiff sought discovery of the producer's beliefs, opinions, intent, and conclusions in preparing the program.
Alan …
Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture
Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture
William & Mary Law Review
No abstract provided.
Determination Of Fair Market Value For Ad Valorem Tax Purposes Of A Gas Lease Burdened With A Long-Term Sales Contract., Jack Lewis Iii
Determination Of Fair Market Value For Ad Valorem Tax Purposes Of A Gas Lease Burdened With A Long-Term Sales Contract., Jack Lewis Iii
St. Mary's Law Journal
Abstract Forthcoming.
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.
Virginia Wealth Transfer Tax- Proposed Alternatives, Michael D. Flemming
Virginia Wealth Transfer Tax- Proposed Alternatives, Michael D. Flemming
University of Richmond Law Review
House Resolution 34, which was approved by the House of Delegates during the 1977 session of the Virginia General Assembly, observed that Virginia's inheritance and gift tax laws have remained essentially unchanged for more than 50 years and commissioned a study of those laws "in light of recent developments."' The proponents of House Resolution 34 no doubt had the 1976 amendments to the federal estate and gift tax laws fresh on their minds. But in addition to the federal changes, several of the states have altered their approach to transfer taxation in recent years. These changes expand the options available …
Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel
Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel
Florida State University Law Review
Income Tax- PROPERTY SETTLEMENT IN DIVORCE- AN UNSETTLED AREA OF SETTLED LAW.
Spooner V. Askew, 345 So. 2d 1055 (Fla. 1976), Charles A. Johnson
Spooner V. Askew, 345 So. 2d 1055 (Fla. 1976), Charles A. Johnson
Florida State University Law Review
Ad Valorem Taxation- RATIFICATION OF FLORIDA'S AD VALOREM TAX STRUCTURE: REJECTION OF AN EQUAL PROTECTION CHALLENGE.
Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran
Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran
UIC Law Review
No abstract provided.
Federal And State Taxation Of Municipal Bond Mutual Funds: A Proposal For A Principled State Response To Amendments To The Code
Maryland Law Review
No abstract provided.
Income Shifting Through A Subchapter S Corporation
Income Shifting Through A Subchapter S Corporation
Maryland Law Review
No abstract provided.
Recent Decisions, Lloyd F. Leroy, Shelley B. O'Neill, Thomas E. Settles
Recent Decisions, Lloyd F. Leroy, Shelley B. O'Neill, Thomas E. Settles
Vanderbilt Journal of Transnational Law
Commodity Futures Trading Commission Act of 1974--Commodity Futures Trading Commission Regulating that Restrict Dealers in Foreign Options More Severely than Dealers in Futures Contracts are not Arbitrary or Capricious
Lloyd F. LeRoy
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Customs--Countervailing Duties--Rebates of Nonexcessive Excise Taxes Do Not Constitute a Bounty Subject to Countervailing Duties
Shelley B. O'Neill
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Jurisdiction--Exercise of in REM and Quasi in Rem Jurisdiction Justified only Where International Shoe Minimum Contacts Standard is Satisfied
Thomas E. Settles
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SECURITIES REGULATION--Extraterritorial Application of the Anti-fraud Provisions--Federal Securities Laws Grant Jurisdiction When There is Some Activity in Furtherance of a Fraudulent Scheme Committed Within the …
Corporate Taxation - Net Operating Loss Carryovers Do Not Make Otherwise Worhtless Stock Valuable In The Hands Of The Corporate Shareholder, Jennifer Berke
Corporate Taxation - Net Operating Loss Carryovers Do Not Make Otherwise Worhtless Stock Valuable In The Hands Of The Corporate Shareholder, Jennifer Berke
Villanova Law Review
No abstract provided.
Material Participation And The Valuation Of Farm Land For Estate Tax Purposes Under The Tax Reform Act Of 1976, David A. Bratt
Material Participation And The Valuation Of Farm Land For Estate Tax Purposes Under The Tax Reform Act Of 1976, David A. Bratt
Kentucky Law Journal
No abstract provided.
Tax Implications Of The Uniform Marriage And Divorce Act: Does The Davis Rule Still Apply In Kentucky?, Susan L. Coleman
Tax Implications Of The Uniform Marriage And Divorce Act: Does The Davis Rule Still Apply In Kentucky?, Susan L. Coleman
Kentucky Law Journal
No abstract provided.
The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek
The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek
Kentucky Law Journal
No abstract provided.