Open Access. Powered by Scholars. Published by Universities.®

Law Commons

Open Access. Powered by Scholars. Published by Universities.®

Taxation-Federal

Journal

1970

Institution
Keyword
Publication

Articles 1 - 21 of 21

Full-Text Articles in Law

Davis V. United States: A Victory For Congressional Intent In The Federal Income Laws, James D. Kemper Oct 1970

Davis V. United States: A Victory For Congressional Intent In The Federal Income Laws, James D. Kemper

Indiana Law Journal

No abstract provided.


Taxation—Tax Benefit Rule Applicable To Section 357 Liquidations, Thomas A. Palmer Oct 1970

Taxation—Tax Benefit Rule Applicable To Section 357 Liquidations, Thomas A. Palmer

Buffalo Law Review

Commissioner v. Anders, 414 F.2d 1283 (10th Cir. 1969).


The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott Oct 1970

The Accumulated Earnings Tax And The Reasonable Needs Of The Business: A Proposal, Homer L. Elliott

William & Mary Law Review

No abstract provided.


The Scope Of Employment Under The Federal Insurance Contributions Act: Included And Excluded Service Sep 1970

The Scope Of Employment Under The Federal Insurance Contributions Act: Included And Excluded Service

Washington and Lee Law Review

No abstract provided.


A Critique Of The Rule-Making Process In Federal Income Tax Law With Special Reference To Conglomerate Acquisitions, William D. Popkin Jul 1970

A Critique Of The Rule-Making Process In Federal Income Tax Law With Special Reference To Conglomerate Acquisitions, William D. Popkin

Indiana Law Journal

No abstract provided.


Civil Rights--Segregation--Federal Income Tax: Exemptions And Deductions--The Validity Of Tax Benefits To Private Segregated Schools, Michigan Law Review Jun 1970

Civil Rights--Segregation--Federal Income Tax: Exemptions And Deductions--The Validity Of Tax Benefits To Private Segregated Schools, Michigan Law Review

Michigan Law Review

In granting the preliminary injunction, the district court found that plaintiffs were asserting a substantial constitutional claim and had a reasonable possibility of success. Balancing the equities of the parties, the court decided that the possibility of significant adverse effect on the Commissioner and schools awaiting tax benefits was not great and was in any event far outweighed by the harm which could result from a denial of the requested relief pendente lite. Thus, the court found that the threat of irreparable injury justified the issuance of a preliminary injunction. The propriety of the court's decision to grant a preliminary …


Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson May 1970

Boot Dividends And The Automatic Rule: Bedford Revisited, Mervyn S. Gerson

William & Mary Law Review

No abstract provided.


The Limitless Limits Of The Foreign Tax Credit, Robert D. Kaplan Apr 1970

The Limitless Limits Of The Foreign Tax Credit, Robert D. Kaplan

Washington Law Review

The purpose of this comment is to describe some of the problems that exist in the present system of foreign tax credits, and to set forth some suggested improvements that can be made. The discussion proceeds in four steps: (1) a description of the growth of the present statutory framework, including a discussion of the political and economic factors which purported to influence its development; (2) an examination of the operation of the credit system and its limitations; (3) an examination of the limitations in greater detail with illustrations of how they are rendered largely impotent by their own internal …


Taxation—Income: Tax Computation Where Taxpayer Refunds Revenues Previously Reported Under Claim Of Right Doctrine.—United States V. Skelly Oil Company, 394 U.S. 678 (1969), Anon Apr 1970

Taxation—Income: Tax Computation Where Taxpayer Refunds Revenues Previously Reported Under Claim Of Right Doctrine.—United States V. Skelly Oil Company, 394 U.S. 678 (1969), Anon

Washington Law Review

In the years 1952 through 1957 the Skelly Oil Company received $505,536.54 from two customers due to a raise in the minimum price for natural gas by the Oklahoma Corporation Commission. In 1958 the Company was required to refund this money due to a vacation of the increased rates by an order of the United States Supreme Court. The Company had included the amounts received in gross income for income tax purposes during the years of receipt in conformance with the claim of right doctrine, whereby amounts received by a taxpayer who claims an unrestricted right to them must be …


Section 367: An Enigma, Julie W. Weston Mar 1970

Section 367: An Enigma, Julie W. Weston

Washington Law Review

Section 367 of the Internal Revenue Code of 1954 was enacted in its original form in 1932 in order to close what Congress considered to be a serious tax loophole available to domestic corporations and individuals carrying on business through the use of foreign corporations or contemplating the use of foreign corporations to realize large gains without paying taxes. The loophole resulted from the operation of the nonrecognition provisions of the Code dealing with the organization and reorganization of corporations. By using these provisions, individuals and corporations—both foreign and domestic—could transfer greatly appreciated property and unrealized profits on a tax-free …


The Life Insurance Company Income Tax Act Of 1959: Tax-Exempt Intercorporate Distributions In Consolidated Filing Mar 1970

The Life Insurance Company Income Tax Act Of 1959: Tax-Exempt Intercorporate Distributions In Consolidated Filing

Washington and Lee Law Review

No abstract provided.


The Transaction Test For Federal Income Tax Loss Deductions Mar 1970

The Transaction Test For Federal Income Tax Loss Deductions

Washington and Lee Law Review

No abstract provided.


Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr. Mar 1970

Professional Associations And Corporations: Tax Considerations, Robert S. Parker Jr., Edmund Polubinski Jr.

William & Mary Law Review

No abstract provided.


Federal Income Tax - Casualty Loss Deduction - Determining The Proper Basis Figure In A Partial Casualty Loss To A Timber Tract - What Is The Single, Idnetifiable Property Damaged Or Destroyed, The Trees Or The Entire Tract?, John W. Bell Jan 1970

Federal Income Tax - Casualty Loss Deduction - Determining The Proper Basis Figure In A Partial Casualty Loss To A Timber Tract - What Is The Single, Idnetifiable Property Damaged Or Destroyed, The Trees Or The Entire Tract?, John W. Bell

Loyola University Chicago Law Journal

No abstract provided.


Taxation- Deductibility Of Contributions To Segregated Private School Jan 1970

Taxation- Deductibility Of Contributions To Segregated Private School

University of Richmond Law Review

Brown v. Board of Education set the stage for an extensive series of activities designed to circumvent the Court's intention to abolish segregated public education. However legally futile many of these endeavors have become, there remains one instrument of education over which the fourteenth amendment is powerless: the private school. Since tuition alone inevitably fails to generate sufficient revenue to fund the necessary expenses of construction and operation, private charitable contributions are needed, and are encouraged by their deductibility for federal income, as well as estate and gift tax purposes.


Recent Legislation Jan 1970

Recent Legislation

University of Richmond Law Review

This is a list of the recent legislation from 1970.


Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton Jan 1970

Taxation—Stipends Given In Conjunction With Employer Doctoral Programs Are Taxable As Compensation For Employment, A. Bruce Norton

Buffalo Law Review

Bingler v. Johnson, 394 U.S. 741 (1969).


An Analysis Of The Taxation Of Stock Dividends From 1918 To 1970; Effects Of The Tax Reform Act Of 1969 On § 305 Of The Internal Revenue Code, Harvey J. Eger Jan 1970

An Analysis Of The Taxation Of Stock Dividends From 1918 To 1970; Effects Of The Tax Reform Act Of 1969 On § 305 Of The Internal Revenue Code, Harvey J. Eger

Duquesne Law Review

On December 10, 1969, the most massive and controversial piece of tax legislation ever proposed was enacted by Congress. One small portion of this act, § 421, has substantially altered the tax status of stock dividends by amending § 305 of the Internal Revenue Code of 1954. As a result, § 305 now covers a wide variety of situations where the receipt of stock dividends previously nontaxable will give rise to income taxable at ordinary rates.


Federal Taxation And Non-Profit Organizations, Marcus Schoenfeld Jan 1970

Federal Taxation And Non-Profit Organizations, Marcus Schoenfeld

Cleveland State Law Review

The Revenue Act of 1969 is one of the greatest overall changes in the revenue laws since the introduction of the federal income tax . Perhaps the most extensive changes were made in the area of tax-exempt organizations. Only some of these changes were within of the topic of this presentation, and some of the other changes in the "charitable" area merit great discussion-for example charitable remainder trusts. Even the topics discussed herein, of necessity were discussed briefly due to lack of time and Regulations. The full the 1969 Act on non-profit organizations will not be apparent for quite some …


The Not-For-Profit Business Corporation, James K. Weeks Jan 1970

The Not-For-Profit Business Corporation, James K. Weeks

Cleveland State Law Review

The Non-Profit Corporation is usually regarded traditionally from a lay and legal viewpoint as one being engaged in charitable, educational, scientific or social work or a religious endeavor. On the other hand, the Not-for-Profit Corporation is more often engaged in enterprises usually associated with functions of a business corporation. However, as soon as one begins to view these corporations from a definitional standpoint, one is bogged down in an incredibly complicated procedure which does little to clarify the confusion.


Federal Income Taxation--Scholarship And Fellowship Grants--Validation Of Treasury Regulation, Leslie C. Smith Jan 1970

Federal Income Taxation--Scholarship And Fellowship Grants--Validation Of Treasury Regulation, Leslie C. Smith

Kentucky Law Journal

No abstract provided.