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Full-Text Articles in Law
Cadillacs, Gold Watches, And The Tax Reform Act Of 1986: The Continuing Evolution Of The Tax Treatment Of Gifts To Employees, Mark W. Cochran
Cadillacs, Gold Watches, And The Tax Reform Act Of 1986: The Continuing Evolution Of The Tax Treatment Of Gifts To Employees, Mark W. Cochran
Akron Tax Journal
The purpose of this article is to explore the historical background underlying the changes in the Tax Reform Act of 1986, to explain the changes, and to assess their meaning and significance?
Traveling Expenses To Temporary Job Sites Kohr V. United States Walraven V. Commissioner, John Ney
Traveling Expenses To Temporary Job Sites Kohr V. United States Walraven V. Commissioner, John Ney
Akron Tax Journal
The issue addressed in this update is the current status of the deductibility of traveling expenses to temporary job sites. The analysis is a comparison of two recent cases: Kohr v. United States I and Walraven v. Commissioner.' Kohr involves the granting of a summary judgment in favor of the taxpayer from the District Court. In Walraven, the Eighth Circuit affirmed a Tax Court ruling in favor of the Commissioner of Internal Revenue. Both cases involve construction workers who maintained residences that were considerable distances from their employment. Both were employed at a nuclear power plant construction project, and both …
Unitary Theory Of Stock Ownership Fink V. Commissioner, Janis Stamm
Unitary Theory Of Stock Ownership Fink V. Commissioner, Janis Stamm
Akron Tax Journal
In Commissioner v. Fink,' the Supreme Court held that a dominant shareholder who voluntarily surrenders a portion of his shares to the corporation, while retaining control, does not sustain an immediate loss deductible for income tax purposes. Such a surrender of stock must be treated as a contribution to capital, the basis of the surrendered shares being reallocated to the remaining shares held and loss or gain recognized only when the shareholder disposes of the remaining shares.
Constructive Receipt Of Income Baxter V. Commissioner, Adam M. Ekonomon
Constructive Receipt Of Income Baxter V. Commissioner, Adam M. Ekonomon
Akron Tax Journal
In Baxter v. Commissioner, the court decided whether taxpayer Baxter had constructively received $13,095 of commissions he had earned in 1978. Baxter, a cash basis taxpayer, received a check in the mail for these commissions in early 1979. The check was dated December 30, 1978. Treasury Regulation Section 1.451-2(a) controls and provides, in part, that a taxpayer constructively receives income when it is otherwise made available to draw upon at any time, even though it is not reduced to the taxpayer's possession. However, there is no constructive receipt if "taxpayer's control of its receipt is subject to substantial limitations or …
26 U.S.C. 501(C)(9) Tax Exempt Status Of Voluntary Employees' Benefit Associations, Tony Paxton
26 U.S.C. 501(C)(9) Tax Exempt Status Of Voluntary Employees' Benefit Associations, Tony Paxton
Akron Tax Journal
This article discusses Canton Police Benevolent Association v. United States and it's implications related to 26 U.S.C. 501(c)(9).
Report On Transfer Tax Restructuring, K. Jay Holdsworth, Ronald D. Aucutt, Edward B. Benjamin Jr., Kenneth W. Bergen, James B. Lewis
Report On Transfer Tax Restructuring, K. Jay Holdsworth, Ronald D. Aucutt, Edward B. Benjamin Jr., Kenneth W. Bergen, James B. Lewis
Akron Tax Journal
This report is submitted to the Council of the Section of Taxation, American Bar Association as a proposed response to the request of the Treasury Department for suggestions for reform of the Federal transfer taxes (the estate, gift, and generation-skipping transfer taxes). That request was contained in a letter dated November 19, 1985, from Ronald A. Pearlman, the Assistant Secretary (Tax Policy), to Hugh Calkins, then Section Chair.' After receiving individual comment papers on the subject from members of the Section's Committee on Estate and Gift Taxes, Mr. Calkins, on April 14, 1986, created this Task Force and asked it …