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Articles 61 - 70 of 70
Full-Text Articles in Law
Deductibility Of Prepaid Idc After Keller, Michael R. Donaldson
Deductibility Of Prepaid Idc After Keller, Michael R. Donaldson
Cleveland State Law Review
In recent years, the Internal Revenue Service has succeeded in eliminating a number of tax-sheltering mechanisms by employing both changes in the tax laws and zealous-some would say overzealous-enforcement of tax law interpretations. While some of these mechanisms may have been abusive, others which were harmless and productive have also fallen victim to the wholesale assault. In July of 1982, with the Tax Court's decision in Keller v. Commissioner, one of the most widespread and traditionally favored tax-shelter vehicles, the oil and gas exploratory drilling fund, was placed on the endangered species list, its ultimate fate as yet undeterminable. Section …
Assessing Internal Revenue Service Jeopardy Procedures: Recent Legislative And Judicial Reforms, Margaret M. Armen
Assessing Internal Revenue Service Jeopardy Procedures: Recent Legislative And Judicial Reforms, Margaret M. Armen
Cleveland State Law Review
Recent events have led thoughtful citizens, jurists, and Congressmen to question the wisdom of allowing the Internal Revenue Service (Service) to assess and collect taxes without prior judicial hearing in those instances in which the revenue is thought to be "in jeopardy." Congress and the Supreme Court have made significant reforms which strengthen a taxpayer's rights against Service intransigence or arrogance with respect to jeopardy assessments. The reforms, the abuses which prompted them, and suggestions for future congressional action are the subject of this Note.
Reflections On The Tax Reform Act Of 1976, Stanley S. Surrey
Reflections On The Tax Reform Act Of 1976, Stanley S. Surrey
Cleveland State Law Review
What should be said in concluding these reflections on the 1976 Tax Reform Act? Overall the verdict must be on the plus side. The Act does achieve reforms in a number of areas and the serious setbacks are relatively few. The credit goes to the reform groups on the Tax Committees and in the Congress, the Budget Committees and the Congressional Budget Office, the Joint Committee Staff, the few public interest groups, the dogged efforts of a few tax reform-minded Representatives and Senators, and in ways not really fully fathomable, to the efforts, differently pursued, of Chairman Ullman and Chairman …
War Tax Refusal: Some Code Problems, William Tabac
War Tax Refusal: Some Code Problems, William Tabac
Law Faculty Articles and Essays
Throughout our history, many individuals and groups have employed tax refusal to make their points. Frustration with government policies and cynicism about the leaders who create them are driving more and more Americans toward radical forms of dissent. Civil disobedience is on the increase and struggling for status among protestors. So far attacks against the "establishment," its mores and property, have alternated between passive law breaking, such as tax and draft refusal, to the increasingly commonplace destruction of that which the protestors detests. But the mix is not equal, and this is demonstrated dramatically in the case of tax refusal. …
War Tax Refusal: Some Code Problems, William Louis Tabac
War Tax Refusal: Some Code Problems, William Louis Tabac
Cleveland State Law Review
Throughout our history, many individuals and groups have employed tax refusal to make their points. ...a protest based on tax refusal has never won a significant number of adherents in this country. There are several reasons for this, but the most pervasive seem to be the fear most people have of going to jail and the confusion that exists in their minds about the limits of the power of the Internal Revenue Service (I.R.S.), that is, what this agency can and cannot do to people who do not pay their taxes. Until some of their doubts are answered, the antiwar …
Section 303 Stock Repurchase Vs. Accumulated Earnings Tax, Mel J. Massey Jr.
Section 303 Stock Repurchase Vs. Accumulated Earnings Tax, Mel J. Massey Jr.
Cleveland State Law Review
This article looks into the situation in which Section 303 is beign planned for use in a corporation that is over-capitalized. "Under its provisions the stockholder of a closely held corporation can look to the corporation to purchase sufficient shares of his stock in order to permit his executor to pay estate and inheritance taxes, executor's and attorney's fees and funeral expenses. The asset, his stock in the closed corporation, which has chiefly caused this stockholder's estate problem, will be used to solve it."
Tax Subchapter S Becomes Clearer, Edward M. Greenwald
Tax Subchapter S Becomes Clearer, Edward M. Greenwald
Cleveland State Law Review
Since the addition of Subchapter S to the 1954 Internal Revenue Code in 1958, many articles have been written on the interpretation and application of the provisions of this Chapter to various factual situations. At the time of their publication, the final Regulations and pertinent Internal Revenue Service Rulings on the subject had not been promulgated. The subsequent promulgation and issuance of these Regulations and Rulings, therefore, had the effect of abrogating many of the proposals which had been advocated in these articles. These Regulations and Rulings did not answer all of the questions, and until such time as there …
Practice Of Taxation: Accountants Vs. Attorneys, Orville J. Weaver
Practice Of Taxation: Accountants Vs. Attorneys, Orville J. Weaver
Cleveland State Law Review
What constitutes the illegal or unauthorized practice of law by accountants in their tax practice? The popular conception of the practice of law is the appearance in courts by attorneys. This may be a very small part of the average attorney's law practice. he spends most of his time in determining his clients' legal problems other than in court. So the unauthorized practice of law concerns itself with activities of persons, other than lawyers, who give legal advice to clients in connection with the practice of their professions. Accountants have prepared federal income tax returns, and returns for various state …
The Analogous Development Of The Fair Trade And Tax Limitation Movements, Frank E. Packard
The Analogous Development Of The Fair Trade And Tax Limitation Movements, Frank E. Packard
Cleveland State Law Review
The Fair Trade Act, or resale price maintenance, movement began in 1913. The movement to limit federal income, gift, and estate tax rates to twenty-five per cent in peacetime commenced in 1939. The fair trade act movement was spearheaded by the American Fair Trade League. The federal income, gift, and estate tax rate limitation movement is spearheaded by the Western Tax Council.
Modification Of Domiciliary State's Power To Tax Vessels Engaged In Interstate Commerce, Sam W. Baker
Modification Of Domiciliary State's Power To Tax Vessels Engaged In Interstate Commerce, Sam W. Baker
Cleveland State Law Review
Standard Oil Co. v. Peck, Tax Commissioner et al., 72 S. Ct. 309 (1952) Held: The ad valorem taxes levied by various states must be fairly apportioned to the commerce carried on within the taxing state. The rule permitting taxation of personal property used in interstate operations by two or more states on an apportionment basis precludes taxation on full value of all such property by the state of domicile.