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Full-Text Articles in Law
"Substantial Justification" Further Defined By Phillips, Jerome S. Horvitz, Annette Hebble
"Substantial Justification" Further Defined By Phillips, Jerome S. Horvitz, Annette Hebble
Akron Tax Journal
The Tax Court in Phillips (referred to as Phillips II) has set helpful guidelines for making a determination of when the IRS has taken a position which is not substantially justified. This is one of the tests that must be satisfied before a court of proper jurisdiction can grant a motion for litigation costs pursuant to Section 7430. Phillips I also addresses the issue of settlement attempts, and whether they are needed to exhaust administrative remedies, which is a further requirement for Section 7430 treatment. The following discussion describes the legislative purpose of Section 7430 and its effectiveness in …
Federal Income Tax Developments: 1982, Merlin G. Briner
Federal Income Tax Developments: 1982, Merlin G. Briner
Akron Tax Journal
This article discusses federal income tax developments in 1982, including relevant Supreme Court cases, oil and gas, tax shelters, deductions, corporations and interest free loans. The Tax Equity and Fiscal Responsibility Act (TERFA) is discussed in a separate section.
Use Of Multiple Qualified Pension Plans By Small Employers After The Tax Equity And Fiscal Responsibility Act Of 1982, Daniel R. Sharpe
Use Of Multiple Qualified Pension Plans By Small Employers After The Tax Equity And Fiscal Responsibility Act Of 1982, Daniel R. Sharpe
Akron Tax Journal
Since the adoption of the Employee Retirement Income Security Act of 1974, many employers have adopted more than one pension or profit sharing plan for a variety of reasons. The rules governing the design and structure of multiple pension plans have remained relatively static since 1974 until the adoption of the Tax Equity and Fiscal Responsibility Act of 1982. This article will explore some of the radical changes made by TEFRA to the design and operation of multiple pension plans, particularly by small employers.
Tax Equity And Fiscal Responsibility Act Of 1982, Merlin G. Briner
Tax Equity And Fiscal Responsibility Act Of 1982, Merlin G. Briner
Akron Tax Journal
O N AUGUST 20, 1982, President Reagan signed into law the Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA), the fourth piece of major tax legislation in less than seven years. Though TEFRA has been said to provide the single largest tax increase in American history, President Reagan lobbied for it not as a tax bill, but as a revenue measure which, to his mind, in no way represented a backing-off from his vaunted "supply side-trickle down" economic program. This article will discuss the implications of TERFA on both the individual taxpayer and businesses.