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Full-Text Articles in Law

Privacy In Taxation, Michael Hatfield Jan 2017

Privacy In Taxation, Michael Hatfield

Florida State University Law Review

No abstract provided.


Tax Whistleblower Statute: Obtaining Meaningful Appeals Through The Appropriate Scope Of Review, Matthew R. Stock Apr 2015

Tax Whistleblower Statute: Obtaining Meaningful Appeals Through The Appropriate Scope Of Review, Matthew R. Stock

Florida State University Law Review

No abstract provided.


Realization And Recognition Of Losses On Stock Surrenders: A Frolic Through Subchapter C, Gwendolyn Griffith Jan 1989

Realization And Recognition Of Losses On Stock Surrenders: A Frolic Through Subchapter C, Gwendolyn Griffith

Florida State University Law Review

A shareholder's surrender of stock to a corporation for no consideration arguably results in a realized loss to the shareholder. But should that loss be recognized? The Supreme Court's decision in Fink v. Commissioner denied loss recognition for stock surrenders resulting in only a small reduction in a shareholder's percentage ownership in a corporation. While correct in results, the analytical basis for this decision is problematic and offers a unique opportunity to examine the basic issues of loss realization and recognition within the context of subchapter C of the Internal Revenue Code.


Improving The Earned Income Credit: Transition To A Wage Subsidy Credit For The Working Poor, Jonathan Barry Forman Apr 1988

Improving The Earned Income Credit: Transition To A Wage Subsidy Credit For The Working Poor, Jonathan Barry Forman

Florida State University Law Review

Millions of American families have incomes that fall below the poverty line. Of these, many families are poor despite the fact that at least one member of these families works during the year. In this article, Professor Forman examines one tool in the fight against poverty, the earned income credit. Professor Forman examines the history of the credit and its shortcoming and then suggests ways in which the credit could be improved to better serve the working poor.


Back From The Dead: How President Reagan Saved The Income Tax, Marvin A. Chirelstein Jul 1986

Back From The Dead: How President Reagan Saved The Income Tax, Marvin A. Chirelstein

Florida State University Law Review

No abstract provided.


Recent Developments In The Federal Tax Law Treatment Of Nominee Corporations, Carla Green Jul 1985

Recent Developments In The Federal Tax Law Treatment Of Nominee Corporations, Carla Green

Florida State University Law Review

No abstract provided.


Section 83 Applied To Partnership Transactions: The Road To Certainty In Planning And Controlling The Tax Consequences Of Exchanges Of Partnership Interests For Services, Charles R. Gehrke Jul 1985

Section 83 Applied To Partnership Transactions: The Road To Certainty In Planning And Controlling The Tax Consequences Of Exchanges Of Partnership Interests For Services, Charles R. Gehrke

Florida State University Law Review

No abstract provided.


Defining "Trade Or Business" Under The Internal Revenue Code: A Survey Of Relevant Cases, E. John Lopez Oct 1984

Defining "Trade Or Business" Under The Internal Revenue Code: A Survey Of Relevant Cases, E. John Lopez

Florida State University Law Review

No abstract provided.


Allison V. United States, 83-1 U.S. Tax Cas. (Cch) ¶ 9241 (Ct. App. Fed. Cir. 1983), Peter Doragh Oct 1983

Allison V. United States, 83-1 U.S. Tax Cas. (Cch) ¶ 9241 (Ct. App. Fed. Cir. 1983), Peter Doragh

Florida State University Law Review

Partnership Taxation-INTANGIBLE DRILLING COSTS MEET SUBSTANTIAL ECONOMIC EFFECT


Partnership Allocations: Flipping Through The Substantial Economic Effect Hoops, Frank Rainer Jul 1983

Partnership Allocations: Flipping Through The Substantial Economic Effect Hoops, Frank Rainer

Florida State University Law Review

No abstract provided.


Eligibility, Election And Termination Under The Subchapter S Revision Act Of 1982, Robert E. Meale Apr 1983

Eligibility, Election And Termination Under The Subchapter S Revision Act Of 1982, Robert E. Meale

Florida State University Law Review

No abstract provided.


Fogelsong V. Commissioner, 691 F.2d 848 (7th Cir. 1982), Timothy L. Whalen Jan 1983

Fogelsong V. Commissioner, 691 F.2d 848 (7th Cir. 1982), Timothy L. Whalen

Florida State University Law Review

Tax-Fogelsong IV: THE SEVENTH CIRCUIT HOLDS THAT A PERSONAL SERVICE CORPORATION AND ITS SOLE SHAREHOLDER/EMPLOYEE DO NOT CONSTITUTE TWO SEPARATE ORGANIZATIONS, TRADES, OR BUSINESSES UNDER SECTION 482 OF THE INTERNAL REVENUE CODE.


Tufts -- The Resurrection Of Crane's Footnote 37, Janet Jacobowitz Oct 1981

Tufts -- The Resurrection Of Crane's Footnote 37, Janet Jacobowitz

Florida State University Law Review

No abstract provided.


The Mortgage Subsidy Bond Tax Act Of 1980: A Step In The Wrong Direction, Joseph Edward Broadus Jul 1981

The Mortgage Subsidy Bond Tax Act Of 1980: A Step In The Wrong Direction, Joseph Edward Broadus

Florida State University Law Review

No abstract provided.


Carnation Co. V. Commissioner, 640 F.2d 1010 (9th Cir. 1981), Jorge E. Alvarez Jul 1981

Carnation Co. V. Commissioner, 640 F.2d 1010 (9th Cir. 1981), Jorge E. Alvarez

Florida State University Law Review

Income Tax-FOREIGN INCOME-INSURANCE PAYMENTS TO WHOLLY-OWNED FOREIGN CAPTIVE INSURANCE COMPANY ARE RECAST AS CAPITAL CONTRIBUTIONS


Ogiony V. Commissioner, 617 F.2d 14 (2d Cir. 1980), Vincent A. Sable Apr 1981

Ogiony V. Commissioner, 617 F.2d 14 (2d Cir. 1980), Vincent A. Sable

Florida State University Law Review

Taxation-DISREGARDING THE CORPORATE ENTITY-PARTNERS UNABLE TO IGNORE EXISTENCE OF CORPORATION USED FOR FINANCING PURPOSES


Of No Interest: Truth, Substance, And Bargain Borrowing, Joseph W. Jacobs Apr 1981

Of No Interest: Truth, Substance, And Bargain Borrowing, Joseph W. Jacobs

Florida State University Law Review

No abstract provided.


Federal Regulation Of Foreign Currency Trading For Future Delivery On Interbank And Futures Markets, Stewart L. Brown, W. Dekle Day Jan 1981

Federal Regulation Of Foreign Currency Trading For Future Delivery On Interbank And Futures Markets, Stewart L. Brown, W. Dekle Day

Florida State University Law Review

No abstract provided.


Federal Income Taxation Of Exchanges In Partition Of Commonly Owned Property: Realization Vs. Realism, Jonathan D. Kaney, Jr. Oct 1980

Federal Income Taxation Of Exchanges In Partition Of Commonly Owned Property: Realization Vs. Realism, Jonathan D. Kaney, Jr.

Florida State University Law Review

No abstract provided.


The Continuing Saga Of Prepaid Feed Expense: The Fat Lady Has Not Sung, James D. Wright, Nancy E. Wright Apr 1980

The Continuing Saga Of Prepaid Feed Expense: The Fat Lady Has Not Sung, James D. Wright, Nancy E. Wright

Florida State University Law Review

No abstract provided.


Murry V. Commissioner, 601 F.2d 892 (5th Cir. 1979), Jorge E. Alvarez Apr 1980

Murry V. Commissioner, 601 F.2d 892 (5th Cir. 1979), Jorge E. Alvarez

Florida State University Law Review

Income Tax-CONDOMINIUM RECREATION FACILITIES-EXCESS RENTAL PAYMENTS TO OWNERS OF RECREATIONAL FACILITIES NOT INCLUDIBLE IN DEVELOPER'S SALES INCOME


Section 302(C)(2): Opportunities And Pitfalls, Michael A. Jones Jan 1980

Section 302(C)(2): Opportunities And Pitfalls, Michael A. Jones

Florida State University Law Review

No abstract provided.


I.R.C. § 302(B)(1): Dividend Equivalency After United States V. Davis, Ronald L. Nelson Jul 1979

I.R.C. § 302(B)(1): Dividend Equivalency After United States V. Davis, Ronald L. Nelson

Florida State University Law Review

No abstract provided.


Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr. Apr 1979

Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr.

Florida State University Law Review

No abstract provided.


Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr. Jan 1979

Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.

Florida State University Law Review

No abstract provided.


Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten Oct 1978

Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten

Florida State University Law Review

No abstract provided.


Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola Jan 1978

Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola

Florida State University Law Review

No abstract provided.


Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel Jan 1978

Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel

Florida State University Law Review

Income Tax- PROPERTY SETTLEMENT IN DIVORCE- AN UNSETTLED AREA OF SETTLED LAW.


Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten Jan 1978

Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten

Florida State University Law Review

Profit Sharing- NEW DEFINITION OF A PARTNERSHIP "PROFITS INTEREST" DISQUALIFIES AN OTHERWISE QUALIFIED PROFIT SHARING PLAN.


Partnership Allocations And Tax Reform, Donald J. Weidner Jan 1977

Partnership Allocations And Tax Reform, Donald J. Weidner

Florida State University Law Review

No abstract provided.