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Full-Text Articles in Law
Fairness And Taxation: The Law Of Deferred Income Recognition For The Members Of Agricultural Cooperatives, Kathryn J. Sedo, Mychal S. Brenden
Fairness And Taxation: The Law Of Deferred Income Recognition For The Members Of Agricultural Cooperatives, Kathryn J. Sedo, Mychal S. Brenden
Akron Tax Journal
This Article examines the application of the principles of income recognition and deferral to agricultural cooperatives and suggests a resolution to current inconsistencies in the law. Recent decisions have brought into question the ability of cooperative members to utilize both the ISA and deferred income agreements. This Article asserts that cooperative members can and should be able to take advantage of such options. Part I provides a general background on agricultural cooperatives and sets out the current legal framework for income recognition and deferral. Part II analyzes the current state of the law in regard to the treatment of cooperatives …
Tax Interpretation, Planning, And Avoidance: Some Linguistic Analysis, Menahem Pasternak, Christophe Rico
Tax Interpretation, Planning, And Avoidance: Some Linguistic Analysis, Menahem Pasternak, Christophe Rico
Akron Tax Journal
No abstract provided.
Analyzing The Schizoid Agency: Achieving The Proper Balance In Enforcing The Internal Revenue Code, Richard Lavoie
Analyzing The Schizoid Agency: Achieving The Proper Balance In Enforcing The Internal Revenue Code, Richard Lavoie
Akron Tax Journal
The purpose of this article is to examine the considerations that should influence the development of appropriate controversy position standards for the Service. In this regard it is crucial to understand the inherent duality in the Service's role. On one hand it is charged with enforcing the Internal Revenue Code (the "Code"), and as a result it attempts to maximize the collection of all legally owed taxes. On the other, the Service is charged with maintaining the efficient and fair operation of the tax system as a whole. The United States federal income tax system is premised on voluntary taxpayer …
The Individual Alternative Minimum Tax And The Intersection Of The Bush Tax Cuts: A Proposal For Permanent Reform, Gabriel Aitsebaomo
The Individual Alternative Minimum Tax And The Intersection Of The Bush Tax Cuts: A Proposal For Permanent Reform, Gabriel Aitsebaomo
Akron Tax Journal
The foregoing article begins with a critical examination of the AMT, its purpose, policy rationale, and the manner that it is calculated. Next, the article discusses the mushrooming number of individuals subject to the AMT, and the author posits that the AMT, in its current form, is neither achieving its intended purpose nor fulfilling its policy objective given the increasing number of unintended middle and upper middle class taxpayers subject to the tax. Next, the author critically examines the Bush tax cuts from 2001 to 2004, and concludes that the Bush tax cuts, and the fact that the AMT parameters …
To Tax Or Not To Tax - That Is The Question In The Midst Of Murphy V. I.R.S., Margarita R. Karpov
To Tax Or Not To Tax - That Is The Question In The Midst Of Murphy V. I.R.S., Margarita R. Karpov
Akron Tax Journal
This note examines § 104(a)(2) and the D.C. Circuit decision in Murphy v. I.R.S. focusing on the need for further guidance on taxation of personal damages. Part II inspects the background of taxation generally and § 104(a)(2) specifically. Additionally, Part II looks at the cases that shaped taxation of personal injury awards and Congress's interpretation of this taxation. Part III discusses the background and judicial response to Murphy's complaint, including the Secretary of Labor's findings, Administrative Law Judge's recommendations, the District Court decision, and the D.C. Circuit arguments and decision. Part IV assesses the reasoning of the D.C. Circuit's decision, …