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Full-Text Articles in Law
The New Application Of Transferee Liability, Robert D. Probasco
The New Application Of Transferee Liability, Robert D. Probasco
Robert Probasco
No abstract provided.
Tefra Audits And Refund Claims, Robert D. Probasco
Tefra Audits And Refund Claims, Robert D. Probasco
Robert Probasco
No abstract provided.
E Tax: The Flat Tax As An Electronic Credit Vat, Daniel S. Goldberg
E Tax: The Flat Tax As An Electronic Credit Vat, Daniel S. Goldberg
Daniel S. Goldberg
The article builds on the Hall-Rabushka Flat Tax and proposes a consumption tax called the “E Tax,” which is an electronically collected credit invoice VAT. The Hall-Rabushka Flat Tax is a two-tier consumption tax that is based on a subtraction method VAT. The Hall-Rabushka nuance, however, allows a deduction for wages as if they were purchases of materials by the employer. Wage earners would be taxed on those wages at rates that could be set as graduated or flat, with or without a zero rate or bracket amount and with or without personal exemptions and deductions. Hall and Rabushka proposed …
An "Outside Limit" For Refund Suits: The Case Against The Tax Exception To The Six-Year Bar On Claims Against The Government, Adam Gustafson
An "Outside Limit" For Refund Suits: The Case Against The Tax Exception To The Six-Year Bar On Claims Against The Government, Adam Gustafson
Adam R.F. Gustafson
Longstanding judicial precedent and the official position of the IRS agree that federal tax refund suits are limited only by the two-year statute of limitations of § 6532(a)(1) of the Internal Revenue Code, which is triggered only when the IRS mails the claimant a notice of disallowance. This Article contends that tax refund litigation is also governed by the six-year limitation of 28 U.S.C. § 2401(a) on “every civil action commenced against the United States,” which is triggered upon the accrual of a claim. The Supreme Court alluded to this dual-limitation scheme in 2008 in United States v. Clintwood Elkhorn …