Open Access. Powered by Scholars. Published by Universities.®
Articles 1 - 7 of 7
Full-Text Articles in Law
Tax Treatment Of Takeover Costs: Supreme Court Responds To Controversy!, Ray A. Knight, Lee G. Knight
Tax Treatment Of Takeover Costs: Supreme Court Responds To Controversy!, Ray A. Knight, Lee G. Knight
Akron Tax Journal
This article reviews the position of the IRS along with the reasoning of the courts - including the Supreme Court's 1992 Indopco, Inc. v. Commissioner decision - concerning the tax treatment of costs incurred in a takeover.
Software Taxation In Ohio, Robert W. Mcgee
Software Taxation In Ohio, Robert W. Mcgee
Akron Tax Journal
For more than a decade after the first software tax case was decided, computer software was uniformly classified as intangible for the purpose of sales, use, and personal property taxes, and therefore exempt from taxation. Then, in 1983, the decisions began to go in the other direction, classifying software as tangible and therefore subject to taxation. Ohio courts have played an early and continuing role in the debate over software taxation. This article provides a brief overview of software taxation in general, summarizes the role Ohio courts have played, and compares and contrasts the Ohio position on software taxation with …
Tax Data Disclosure Under The Freedom Of Information Act: Evolution, Issues And Analysis, Mark A. Segal
Tax Data Disclosure Under The Freedom Of Information Act: Evolution, Issues And Analysis, Mark A. Segal
Akron Tax Journal
In this article an examination and analysis is made of the major provisions of the FOIA, of how the FOIA has been applied in the tax area, and of major emerging issues concerning the FOIA. Particular attention is accorded to the common clash of the FOIA's policy of disclosure with I.R.C. § 6103's general rule of confidentiality and nondisclosure of tax return data.
United States Federal Tax Policy Surrounding The Investment Tax Credit: A Review Of Legislative Intent And Empirical Research Findings Over Thirty Years (1962-1991), Robert E. Rosacker, Richard W. Metcalf
United States Federal Tax Policy Surrounding The Investment Tax Credit: A Review Of Legislative Intent And Empirical Research Findings Over Thirty Years (1962-1991), Robert E. Rosacker, Richard W. Metcalf
Akron Tax Journal
Congress enacts tax legislation amidst numerous concerns beyond mere revenue raising. Significant congressional tax policy consideration is conferred upon social objectives, equity concerns, administrative matters, and macroeconomic goals. Within the purview of macro-economic goals can be found federal tax policy relating to investments in fixed assets - which assets are depreciable, the allowable depreciation methods, depreciable lives, and the investment tax credit. Federal tax policy concerning the investment tax credit (ITC) is the topic of this article.
The Service's Latest Attempt To Regulate Hospital-Physician Relationships: A Critical Analysis, Patrick H. Lucas
The Service's Latest Attempt To Regulate Hospital-Physician Relationships: A Critical Analysis, Patrick H. Lucas
Akron Tax Journal
The Chief Counsel of the exempt organization division of the Internal Revenue Service concluded in the General Counsel Memorandum that each of these rulings should be revoked for three reasons: (1) The transactions violated the proscription against inurement of an exempt organization's earnings to any private individual; (2) the transactions infringed upon the doctrine that an organization must operate for public rather than private benefit in order to be exempt from the income tax; and (3) the transactions may violate federal law and that such violations are inconsistent with exemption from the income tax. Each of these theories is examined …
The Unrelated Business Income Tax And Its Effects Upon Collegiate Athletics, Frank James Vari
The Unrelated Business Income Tax And Its Effects Upon Collegiate Athletics, Frank James Vari
Akron Tax Journal
This article examines the Unrelated Business Income Tax and its application to corporate sponsorship of college football bowl games and other exempt organizations likely to be affected by Technical Advice Memorandum 91-47-007. Thereafter, the article will consider the IRS's proposed examination guidelines of corporate sponsorship income, the public policy concerns regarding such income, and the proposed legislation introduced to address the competing concerns.
The Entertainment Facility Rules Of Section 274 And Corporate-Owned Condominiums, Mary E. Vandenack
The Entertainment Facility Rules Of Section 274 And Corporate-Owned Condominiums, Mary E. Vandenack
Akron Tax Journal
In the past decade Congress has focused a lot of attention on limiting or eliminating deductions for lavish entertainment. An area where deductions have been virtually eliminated is that of "entertainment facilities." This Article examines the disallowance provisions of I.R.C. § 274 concerning entertainment facilities in the context of corporate-owned entertainment facilities.