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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
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
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
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
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
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
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
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
"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
Section 482 And The Integrated Business Enterprise, John W. Lee
Faculty Publications
No abstract provided.
Planning Ahead In Tax Administration, Thomas C. Atkeson
Planning Ahead In Tax Administration, Thomas C. Atkeson
Faculty Publications
No abstract provided.