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Taxation-Federal

1992

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Articles 1 - 18 of 18

Full-Text Articles in Law

Recent Developments - Taxation Of Individuals, Partnerships, Estates And Trusts And Exempt Organizations, Meade Emory Dec 1992

Recent Developments - Taxation Of Individuals, Partnerships, Estates And Trusts And Exempt Organizations, Meade Emory

William & Mary Annual Tax Conference

No abstract provided.


Standards Of Tax Practice Accuracy-Related Penalties; Aba Opinion 85-352, J. Timothy Philipps Dec 1992

Standards Of Tax Practice Accuracy-Related Penalties; Aba Opinion 85-352, J. Timothy Philipps

William & Mary Annual Tax Conference

No abstract provided.


Doping Out The Capitalization Rules After Indopco, John W. Lee Nov 1992

Doping Out The Capitalization Rules After Indopco, John W. Lee

Faculty Publications

In this article, Lee provides guidance for Treasury and the IRS (in their promised clarification of application of INDOPCO). He delineates how to avoid what he perceives as the past pitfalls of capitalization of recurring, insubstantial, or relatively short-lived expenditures with Ito, or inadequate, amortization. The article also sets forth models for (a) amortizing as. a freestanding deferred charge long-lived substantial self-created intangibles such as business expansion costs, including employee training costs, and (b) expensing, or perhaps better, amortizing currently less substantial or regularly recurring, steady state self-created intangibles (such as repairs and advertising, respectively).


Why Congress Needs To Fix The Employee/Independent Contractor Tax Rules: Principles, Perceptions, Problems, And Proposals, Walter H. Nunnallee Oct 1992

Why Congress Needs To Fix The Employee/Independent Contractor Tax Rules: Principles, Perceptions, Problems, And Proposals, Walter H. Nunnallee

North Carolina Central Law Review

No abstract provided.


Avoiding Self-Employment Tax, Neil Harl Jul 1992

Avoiding Self-Employment Tax, Neil Harl

Agricultural Law Digest

Two recent private letter rulings issued about a month apart in late 1991 have provided additional guidance on the IRS national office position on two of the strategies used to avoid self-employment tax. In both rulings, the IRS position was adverse to the taxpayers.


Federal Taxation, Steven C. Evans Jul 1992

Federal Taxation, Steven C. Evans

Mercer Law Review

The federal tax cases decided by the Eleventh Circuit during 1991 reversed one trend and continued another trend of 1990. The Eleventh Circuit decided a number of procedural tax cases during 1991. This trend is similar to the number of procedural cases decided in years prior to 1990, but is substantially more than the number of procedural cases decided by the Eleventh Circuit in 1990. Cases decided under the Employment Retirement Income Security Act of 1974 ("ERISA"), as amended, continued to constitute the majority of the substantive tax cases decided by the Eleventh Circuit during 1991.


Tax Expenditure Budgets: A Critical View, Jeffrey S. Lehman, Douglas A. Kahn Mar 1992

Tax Expenditure Budgets: A Critical View, Jeffrey S. Lehman, Douglas A. Kahn

Cornell Law Faculty Publications

No abstract provided.


Income Tax Rhetoric (Or Why Do We Want Tax Reform?), Beverly I. Moran Jan 1992

Income Tax Rhetoric (Or Why Do We Want Tax Reform?), Beverly I. Moran

Vanderbilt Law School Faculty Publications

The 1992 presidential election is over but the United States economy still faces hard times. Each man who hoped to lead us promised to revive our sick economy, and each cure promised included a strong dose of tax reform. At no time during the campaign or the transition did anyone seem to ask: Can tax reform actually increase employment, lower the deficit, nwerse our trade imbalance, or provide any other boost out of the recession? Why do Americans accept the notion that economic recovery requires tax reform? We did not always think this way. Why does it seem so natural ...


Is An Employment-Discrimination Award Taxable?, L. Scott Stafford Jan 1992

Is An Employment-Discrimination Award Taxable?, L. Scott Stafford

Faculty Scholarship

No abstract provided.


Corporate Integration: Do The Uncertainties Outweigh The Benefits?, Reed Shuldiner Jan 1992

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

Faculty Scholarship at Penn Law

No abstract provided.


Does Treasury Have Authority To Index Basis For Inflation?, Lawrence A. Zelenak Jan 1992

Does Treasury Have Authority To Index Basis For Inflation?, Lawrence A. Zelenak

Faculty Scholarship

In this article he examines the claim, which has been publicized in recent months, that the Treasury Department could unilaterally index the capital gains tax for inflation by a new regulation interpreting code section 1012. He concludes, in light of more than seven decades of administrative, judicial and legislative history, that such unilateral action would be invalid.


Commentary: The Tax Legislative Process -- A Critical Need, William D. Popkin Jan 1992

Commentary: The Tax Legislative Process -- A Critical Need, William D. Popkin

Articles by Maurer Faculty

No abstract provided.


Tax Policy And Panda Bears, Douglas A. Kahn, Jeffrey S. Lehman Jan 1992

Tax Policy And Panda Bears, Douglas A. Kahn, Jeffrey S. Lehman

Articles

In this article. Professors Kahn and Lehman argue that the concept of tax expenditure is flawed as a tool for measuring the propriety of tax provisions. It assumes the existence of on true and correct standard of federal income taxation that applies to all circumstances. To make that a assumption, the proponents of the concept implicitly make a particular moral claim about the relative importance of a wide range of values, including efficiency, consumption/savings neutrality, privacy, distributional equity, administrabiliy, charity, and pragmatism. They then measure a tax provision's "normalcy" exclusively by how it conforms to their Platonic concept ...


Controlling Congress: Presidential Influence In Domestic Fiscal Policy, Michael A. Fitts, Robert Inman Jan 1992

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

Faculty Scholarship at Penn Law

No abstract provided.


A General Approach To The Taxation Of Financial Instruments, Reed Shuldiner Jan 1992

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

Faculty Scholarship at Penn Law

No abstract provided.


Tax Expenditure Budgets: A Critical View, Douglas A. Kahn, Jeffrey S. Lehman Jan 1992

Tax Expenditure Budgets: A Critical View, Douglas A. Kahn, Jeffrey S. Lehman

Articles

During the past few months, Tax Notes has featured an extended discussion about the "normalcy" (or lack thereof) of accelerated depreciation. Two contributions to that discussion came from Professor Calvin Johnson of the University of Texas Law School, who disagreed with certain aspects of an article that Professor Kahn wrote in 1979. And the debate shows no sign of slowing down. The interchange over the details of accelerated depreciation offers a useful backdrop against which to consider a more general issue: the intellectual coherence of the tax expenditure budgets. The larger concept of tax expenditures was what motivated Kahn to ...


Taxation, Negative Amortization And Affordable Mortgages, Michael S. Knoll Jan 1992

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

Faculty Scholarship at Penn Law

No abstract provided.


Federal Income Tax Project: International Aspects Of United States Income Taxation Ii: Proposals Of The American Law Institute On United States Income Tax Treaties, Hugh Ault, David Tillinghast Dec 1991

Federal Income Tax Project: International Aspects Of United States Income Taxation Ii: Proposals Of The American Law Institute On United States Income Tax Treaties, Hugh Ault, David Tillinghast

Hugh J. Ault

No abstract provided.