Law Commons^™

Indexing The Tax Code, Reed Shuldiner

All Faculty Scholarship

No abstract provided.

Taxation, Negative Amortization And Affordable Mortgages, Michael S. Knoll

All Faculty Scholarship

No abstract provided.

Corporate Integration: Do The Uncertainties Outweigh The Benefits?, Reed Shuldiner

All Faculty Scholarship

No abstract provided.

A General Approach To The Taxation Of Financial Instruments, Reed Shuldiner

All Faculty Scholarship

No abstract provided.

Controlling Congress: Presidential Influence In Domestic Fiscal Policy, Michael A. Fitts, Robert Inman

All Faculty Scholarship

No abstract provided.

Taxing Service Partners To Achieve Horizontal Equity, Henry Ordower

All Faculty Scholarship

Argues that recent judicial and administrative decisions cause the federal income tax law to tax partners who receive their partnership interests in exchange for services more favorably than partners who acquire their partnership interests in exchange for money or property. Such dissimilar treatment undercuts the desired taxation objective of even-handed treatment of all taxpayers.

The Second Generation Of Notes Indexed For Inflation, Michael S. Knoll

All Faculty Scholarship

No abstract provided.

Shifting Of Income Within The Family: Will 1986 I.R.C. Changes Bring Significant Reform, John A. Lynch Jr.

All Faculty Scholarship

In challenging Congress and the citizenry to embrace tax reform, President Reagan stated:

While most Americans labor under excessively high tax rates that discourage work and cut drastically into savings, many are able to exploit the tangled mass of loopholes that has grown up around our tax code to avoid paying their fair share-sometimes to avoid paying any taxes at all.

Fairness and simplicity were clearly overriding objectives of the tax reform movement that culminated in the Tax Reform Act of 1986.

From the perspectives of both fairness and simplicity, one of the most egregious features of prior law was …

Below Market Loans: From Abuse To Misuses – A Sports Illustration, Phillip J. Closius, Douglas K. Chapman

All Faculty Scholarship

Below market loans have been traditionally used as substitutes for gifts, salaries, and dividends for the primary purpose of tax avoidance in the transfer of wealth. The Supreme Court's opinion in Dickman v. Commissioner subjected both demand and term loans in an intrafamilial setting to the federal gift tax. Congress, while subjecting all below market loans to either income or gift tax, applied different valuation formulas to term and demand loans and, in so doing, favored the use of demand loans as a salary substitute. This Article analyzes the current status of below market loans by examining their use in …

Gerontology And The Law: A Selected Bibliography, 1948-85 Update, Pauline M. Aranas, Mary Jo Brazil, Paul M. George

All Faculty Scholarship

No abstract provided.

Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.

All Faculty Scholarship

As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies the tax treatment of the various types of payments that a partnership may make to a withdrawing partner. It introduced the concept of a liquidation of a partnership interest by the partnership itself, as opposed to the sale of that interest to an outsider or to the continuing partners. In some instances it provides tax consequences for continuing and withdrawing partners which are different from those attendant to a sale. It was designed to make the law concerning disposition of partnership interests simpler and …