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Questions The Irs Will Not Answer, Emily L. Cauble
Questions The Irs Will Not Answer, Emily L. Cauble
Indiana Law Journal
When a taxpayer plans to undertake a transaction and its tax consequences are unclear, the taxpayer can request a letter ruling from the IRS. The IRS issues numerous letter rulings each year. In 2020, for instance, the IRS issued 777 letter rulings. The IRS refrains from issuing letter rulings on certain topics. At the beginning of each year, the IRS publishes an updated list of the topics on which it will not rule. Many of the topics on which it will not rule arise in areas of tax law governed by standards where the tax outcome depends heavily on each …
Bc Ranch Ii V. Commissioner: A Flexible Approach To Perpetual Conservation Easements, Victoria Wolfe
Bc Ranch Ii V. Commissioner: A Flexible Approach To Perpetual Conservation Easements, Victoria Wolfe
Indiana Law Journal
Depending on the approach used in enforcement, there is the potential to encourage or discourage charitable donations of conservation easements. In Part I, this Note explores the federal charitable income tax deduction for conservation easements and the legislative purpose in enacting the perpetuity requirements. Part II examines the Fifth Circuit’s decision in BC Ranch II and the flexible approach to perpetuity adopted by the court. Finally, Part III considers the implications of the BC Ranch II decision, specifically authority to monitor conservation easements, valuation gaming of easements in the context of perpetuity, and congressional intent in allowing the conservation easement …
The Taxpayer's Third Personality: Comments On Redlark V. Commissioner, William D. Popkin
The Taxpayer's Third Personality: Comments On Redlark V. Commissioner, William D. Popkin
Indiana Law Journal
No abstract provided.
Federal Income Tax-Liquidation-Re-Incorporation: The Current Approach And A Proposed Alternative, A. Ennis Dale
Federal Income Tax-Liquidation-Re-Incorporation: The Current Approach And A Proposed Alternative, A. Ennis Dale
Indiana Law Journal
No abstract provided.
Income Tax Differentials: A Symposium, Willard H. Pedrick
Income Tax Differentials: A Symposium, Willard H. Pedrick
Indiana Law Journal
No abstract provided.
Taxation Of Imaginary Profits Under The Federal Income Tax Law Of 1926, Kenneth B. Bond
Taxation Of Imaginary Profits Under The Federal Income Tax Law Of 1926, Kenneth B. Bond
Indiana Law Journal
No abstract provided.