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Articles 151 - 160 of 160

Full-Text Articles in Law

Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee Jan 1976

Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee

Faculty Publications

The IRS in three Rulings has taken the position that services for the distributing corporation performed through independent contractor could not satisfy the active business requirement test of Section 355. Mr. Lee analyzes the Rulings in light of case law and legislative history that have interpreted the Code's active business test. He concludes that further court tests will be necessary before there can be complete reliance upon active conduct by an independent contractor.


The "Active Business" Test Of Section 355: Implications Of A Trilogy Of Revenue Rulings, John W. Lee Jul 1974

The "Active Business" Test Of Section 355: Implications Of A Trilogy Of Revenue Rulings, John W. Lee

Faculty Publications

No abstract provided.


Pre-Operating Expenses And Section 174: Will "Snow" Fall?, John W. Lee Apr 1974

Pre-Operating Expenses And Section 174: Will "Snow" Fall?, John W. Lee

Faculty Publications

No abstract provided.


A Blend Of Old Wines In A New Wineskin: Section 183 And Beyond, John W. Lee Jan 1974

A Blend Of Old Wines In A New Wineskin: Section 183 And Beyond, John W. Lee

Faculty Publications

No abstract provided.


Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee Oct 1972

Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee

Faculty Publications

No abstract provided.


Functional Divisions And Other Corporate Separations Under Section 355 After Rafferty, John W. Lee Jul 1972

Functional Divisions And Other Corporate Separations Under Section 355 After Rafferty, John W. Lee

Faculty Publications

No abstract provided.


Ca-7'S "Wisconsin Big Boy" Case Has Dire Implications In 482 Area, John W. Lee Jan 1972

Ca-7'S "Wisconsin Big Boy" Case Has Dire Implications In 482 Area, John W. Lee

Faculty Publications

The Seventh Circuit, in Wisconsin Big Boy, has recently indicated that arm's-length charges may not prevent a Section 482 reallocation among integrated multiple corporations. Mr. Lee analyzes this recent development and suggests that in the future the proper defense to a 482 attack may lie in a reasonable division of profits.


"Active Conduct" Distinguished From "Conduct" Of A Rental Real Estate Business, John W. Lee Jan 1972

"Active Conduct" Distinguished From "Conduct" Of A Rental Real Estate Business, John W. Lee

Faculty Publications

No abstract provided.


Section 482 And The Integrated Business Enterprise, John W. Lee Jan 1971

Section 482 And The Integrated Business Enterprise, John W. Lee

Faculty Publications

No abstract provided.


Planning Ahead In Tax Administration, Thomas C. Atkeson Jan 1952

Planning Ahead In Tax Administration, Thomas C. Atkeson

Faculty Publications

No abstract provided.