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Articles 1 - 11 of 11
Full-Text Articles in Law
Selected Significant Income Tax Developments In 1965, Leo A. Diamond
Selected Significant Income Tax Developments In 1965, Leo A. Diamond
William & Mary Annual Tax Conference
No abstract provided.
Legal Fees For Unsuccessful Defense To Criminal Prosecution—An "Ordinary And Necessary" Business Expense?, Anon
Washington Law Review
Taxpayer, a securities dealer, was tried and convicted of mail fraud and of fraud under the 1933 Securities Act, and conspiracy to violate these statutes. Thereafter he claimed a tax deduction for legal costs incurred in his defense under the "ordinary and necessary" business expense provision in section 162 of the Internal Revenue Code. The deduction was disallowed by the Commissioner, and this ruling was sustained by the Tax Court. On appeal, the Second Circuit Court of Appeals reversed. Held: Public policy does not preclude the deduction of legal expenses incurred in an unsuccessful criminal defense arising out of, proximately …
The Imputed Sale And Anticipatory Assignment Of Income Doctrines: Their Effect On Irc §§ 311 & 336, Thomas L. David
The Imputed Sale And Anticipatory Assignment Of Income Doctrines: Their Effect On Irc §§ 311 & 336, Thomas L. David
Buffalo Law Review
No abstract provided.
Tax Depreciation Deductions In Year Of Sale
Tax Depreciation Deductions In Year Of Sale
Washington and Lee Law Review
No abstract provided.
The Definition Of "Domestic Building And Loan Association"--Final Tax Regulations, Paul E. Goodspeed
The Definition Of "Domestic Building And Loan Association"--Final Tax Regulations, Paul E. Goodspeed
Michigan Law Review
It will be the purpose of this discussion to examine the newly adopted regulations and to evaluate their effects in the light of congressional intent regarding the statutory definition. Special emphasis will be placed on the quantitative tests established in the regulations, with respect to which two changes will be proposed.
Federal Tax Liens: Evolution And Conflict With State Liens, Samuel Oppenheim
Federal Tax Liens: Evolution And Conflict With State Liens, Samuel Oppenheim
Duquesne Law Review
From the standpoint of the taxpayer, problems dealing with taxation consist primarily of what is taxable, how is it taxable, and to whom is it taxable with the desired result being to pay the legally justifiable minimum to the government. From the government's point of view, the primary problem is (or should be) to impose taxes among all citizens and residents in a fair and equitable manner. If we assume that this state of perfection has been attained, there is yet another problem-the collection of the tax due from the taxpayer to the government. An important tool in the hands …
Initial Impressions Of The Treasury Report On Foundations, Marcus Schoenfeld
Initial Impressions Of The Treasury Report On Foundations, Marcus Schoenfeld
Cleveland State Law Review
Very recently in the United States Treasury Department submitted its study of private foundations to Congress. This is the most recent development in an attempt to delineate the proper role of foundations and their donors in our society, and more particularly their proper tax treatment. Although it is much too soon to predict the effect of the Treasury Report, since Congress itself asked for the study, it is quite likely that some more restrictive legislation will result.
Federal Tax Returns As Evidence In Non-Tax Cases, Laurence Glazer
Federal Tax Returns As Evidence In Non-Tax Cases, Laurence Glazer
Cleveland State Law Review
Many cases deal with the use of Federal tax returns in non-tax cases. The inherent danger in subjecting tax returns to discovery at pre-trial and admission at trial, is the unnecessary disclosure of confidential information. Yet, when income tax returns are material and relevant to the claims of the parties litigant, a contention of privileged communication should not be used to defeat justice.
Some Problems In Liquidating Personal Holding Companies, Elliott H. Kajan, Martin C. Spector
Some Problems In Liquidating Personal Holding Companies, Elliott H. Kajan, Martin C. Spector
Cleveland State Law Review
Ordinarily, distributions by a personal holding company qualify for the dividends paid deduction only if they are "dividends" under section 316. However, certain distributions in liquidation may also qualify. These liquidating distributions of a personal holding company are divided into two categories: (1) Distributions to the extent of earnings and profits for the taxable year (computed without regard to capital losses) made in complete liquidation of the corporation occurring within 24 months after the adoption of the plan of liquidation; and (2) distributions in liquidation properly chargeable to earnings and profits accumulated after February 28, 1913.
Rira -- A Legal Information System In The Internal Revenue Service, David T. Link
Rira -- A Legal Information System In The Internal Revenue Service, David T. Link
Journal Articles
The IRS legal information retrieval program is still in its infancy. The results of its use so far indicate that the program is on a sound foundation. Consequently, the Office has great hopes for it. By eliminating a great deal of the duplication of effort among the attorneys it promises to result in certain economies to the Office. More important, it should assure a more consistent treatment of taxpayers through greater coordination than has ever been possible in the past. And most important, by providing more comprehensive and timely decision-making information the system should further the Offices constant goal of …
Personal Holding Companies And The Revenue Act Of 1964, Jerome B. Libin
Personal Holding Companies And The Revenue Act Of 1964, Jerome B. Libin
Michigan Law Review
By 1964, many years had elapsed since significant changes were made in the federal income tax treatment of so-called "personal holding companies." For that reason alone, any amendments contained in the Revenue Act of 1964 that dealt with personal holding companies would have deserved attention. But the fact is that the changes made by the 1964 Act are so powerful in their thrust that they require the most careful kind of study by every practitioner charged with advising closely held corporations. Since the new provisions are rather complicated in nature, such a study cannot lead to a full understanding of …