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Full-Text Articles in Law

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.


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.


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).