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Full-Text Articles in Law
And The 1999 Award For The Worst Opinion In A Tax Case Goes To -, Deborah A. Geier
And The 1999 Award For The Worst Opinion In A Tax Case Goes To -, Deborah A. Geier
Law Faculty Articles and Essays
This article critiques the opinion in Owen v. United States by Judge Jerome Turner of the Western District of Tennessee.
Tufts And The Evolution Of Debt-Discharge Theory, Deborah A. Geier
Tufts And The Evolution Of Debt-Discharge Theory, Deborah A. Geier
Law Faculty Articles and Essays
This 1992 article first explores how the concept of - 61(a)(12) debt-discharge income evolved over time from a "balance sheet improvement" rationale to one recognizing that what is properly measured under - 61(a)(12) is the prior receipt that would have been a wealth accession at that time if not for the absolute obligation to repay (without regard to balance sheet consequences). The article then goes on to explore how the Supreme Court created unnecessary mischief in Tufts v. Commissioner, 461 U.S. 300 (1983), by failing to recognize the critical differences between - 1001 "gain" or "loss" and - 61(a)(12) debt-discharge …