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Inheritance Taxation - Selected Provisions Of Michigan, Illinois And Ohio - A Study In Application And Justification, Edward B. Stulberg S.Ed.
Inheritance Taxation - Selected Provisions Of Michigan, Illinois And Ohio - A Study In Application And Justification, Edward B. Stulberg S.Ed.
Michigan Law Review
This comment will explore the existing variations in four commonly encountered areas: joint interests with rights of survivorship, contingent remainder interests, powers of appointment, and life insurance proceeds. Emphasis will also be placed on treatment accorded the surviving spouse and children and the implicit relationship between such treatment and some of the above areas. The essence of this examination will be to inquire whether adoption of an estate tax would be a more suitable vehicle for implementing a local death tax program.
Apportionment Of The Federal State Tax In The Absence Of Statute Or An Expression Of Intention, William P. Sutter
Apportionment Of The Federal State Tax In The Absence Of Statute Or An Expression Of Intention, William P. Sutter
Michigan Law Review
Federal law now provides in sections 826 (c) and (d) of the Internal Revenue Code that life insurance and property transferred by appointment shall bear their proportionate tax burden. It does not contain similar provisions with respect to other types of non-probate property. At the present time, twenty states provide by statute for some sort of apportionment of estate taxes. Two states have statutes restricting apportionment in some degree. In the rest, the matter rests in the discretion of the courts. I propose to discuss in this article the situation in those areas where no statutory guidance exists.
Taxation-The Lincoln Electric Question: Must "Ordinary And Necessary" Business Expenses Be Also "Reasonable" In Amount, R. Lawrence Storms S. Ed.
Taxation-The Lincoln Electric Question: Must "Ordinary And Necessary" Business Expenses Be Also "Reasonable" In Amount, R. Lawrence Storms S. Ed.
Michigan Law Review
The United States Court of Appeals for the Sixth Circuit has recently determined in Commissioner v. Lincoln Electric Co. that the element of reasonableness is inherent in the phrase "ordinary and necessary" as used in the paragraph of the Internal Revenue Code authorizing deductions for business expenses. It will be of interest to develop the history of the case throughout its ten years of litigation, to examine some of the collateral points raised, and to attempt a critique of the merits of the court's position.