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Federal Income Tax—Amoritization And The Expansion Sports Franchise—First Northwest Industries Of America, Inc. V. Commissioner, 70 T.C. 817 (1978), Roberta Reiff Katz
Federal Income Tax—Amoritization And The Expansion Sports Franchise—First Northwest Industries Of America, Inc. V. Commissioner, 70 T.C. 817 (1978), Roberta Reiff Katz
Washington Law Review
This note will first discuss past taxation practices of professional sports franchises. It will explain the "mass asset theory" as it has been applied to intangible assets outside the sports context and then examine the conflicting positions of the IRS and the Sonics as to the theory's applicability to the expansion franchise. Next, it will discuss the Tax Court's reasons for deciding not to apply the theory in First Northwest and suggest that the Ninth Circuit should similarly conclude that the theory is inappropriate in the context of expansion franchises. Finally, the note will explain the primary problem that results …
Issues In Federal, State, And Tribal Taxation Of Reservation Wealth: A Survey And Economic Critique, Russel Lawrence Barsh
Issues In Federal, State, And Tribal Taxation Of Reservation Wealth: A Survey And Economic Critique, Russel Lawrence Barsh
Washington Law Review
This article will consider the most important Indian tax decisions, comparing the intended results of the decisions in the context of congressional Indian law with their probable economic consequences. Part II briefly reviews the main factors essential for proper economic evaluation of a tax. Part III critically surveys recent law of federal taxation of reservation wealth. Part IV similarly surveys and criticizes decisions regarding state taxation of reservation wealth. Part V offers alternate resolutions for state-Indian taxation disputes. In Part VI, the article proposes a framework for applying tax economics productively to the problem of meeting tribal revenue needs.