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Articles 1 - 17 of 17
Full-Text Articles in Law
Federal Tax Rulings: Procedure And Policy, Saul C. Belz
Federal Tax Rulings: Procedure And Policy, Saul C. Belz
Vanderbilt Law Review
The rulings program of the Internal Revenue Service was designed to meet the need for predictability of the tax consequences of any given financial transaction. Though the rulings program is not particularly important to the average taxpayer, it has become increasingly crucial both to the financial community and to the Service itself. As the tax laws become more complex, and tax risks become increasingly important to the success of business ventures, the need for confirmation before entering into a transaction is intensified. Thus parties to a transaction will generally request a ruling...
"whenever the answer is uncertain or when the …
Income Tax--Recovered Property Previously Deducted Included In Gross Income In Year Of Recovery--Alice Phelan Sullivan Corp. V. United States, Michigan Law Review
Income Tax--Recovered Property Previously Deducted Included In Gross Income In Year Of Recovery--Alice Phelan Sullivan Corp. V. United States, Michigan Law Review
Michigan Law Review
In 1989 and 1940 the corporate taxpayer claimed as charitable deductions the value of two parcels of realty which it had donated to a charitable organization subject to the condition that they be used solely for religious or educational purposes. Having decided not to use the gifts in the manner specified, the donee reconveyed them to the taxpayer in 1957. The taxpayer failed to reflect this recovery in its gross income for that year. The Commissioner of Internal Revenue, however, determined that under section 111 of the 1954 Internal Revenue Code (Code) the taxpayer's gross income reported in its 1957 …
The Deductibility Of Educational Expenses: Administrative Construction Of Statute, Richard C. Spencer
The Deductibility Of Educational Expenses: Administrative Construction Of Statute, Richard C. Spencer
Buffalo Law Review
No abstract provided.
Advance Payments And The Accrual Taxpayer
Advance Payments And The Accrual Taxpayer
Washington and Lee Law Review
No abstract provided.
U.S. Taxation Of U.S. Real Estate Owned By Nonresident Aliens And Foreign Corporations, Robert B. Alexander Jr.
U.S. Taxation Of U.S. Real Estate Owned By Nonresident Aliens And Foreign Corporations, Robert B. Alexander Jr.
University of Miami Law Review
No abstract provided.
Income Tax- Corporations-Legal Expenses Incurred In Sale Of Assets Pursuant To A Section 337 Liquidation Are Deductible-United States V. Mountain States Mixed Feed Co., Michigan Law Review
Income Tax- Corporations-Legal Expenses Incurred In Sale Of Assets Pursuant To A Section 337 Liquidation Are Deductible-United States V. Mountain States Mixed Feed Co., Michigan Law Review
Michigan Law Review
In 1961, the stockholders of the Mountain States Mixed Feed Co. voted to liquidate the corporation in such a way as to comply with the requirements of section 337 of the Internal Revenue Code of 1954 (Code). That section provides that if a corporation adopts a plan of complete liquidation, and then within twelve months distributes all its assets, it will not recognize a gain or loss for income tax purposes from the sale or exchange of certain types of property. The corporation sold all of its assets and qualified for non-recognition treatment under section 337. It then claimed a …
Assumption And Discharge Of Seller's Liabilities As Year Of Sale Payments For Purposes Of I.R.C. Section 453, David C. Horan
Assumption And Discharge Of Seller's Liabilities As Year Of Sale Payments For Purposes Of I.R.C. Section 453, David C. Horan
Buffalo Law Review
No abstract provided.
The Capital Nature Of Educational Expenses, Anon
The Capital Nature Of Educational Expenses, Anon
Washington Law Review
Taxpayer, a practicing psychiatrist and part-time teacher of psychiatry, undertook a six year training program in psychoanalysis at the Boston Psychoanalytic Institute. In 1961, he deducted $3,650 paid in fees to the Institute as a business expense under section 162 of the Internal Revenue Code. Although taxpayer contended that the expenses were incurred primarily to maintain or improve skills required in his profession, the Commissioner disallowed the deduction. A sharply divided Tax Court upheld the disallowance, relying on two prior cases holding that when a psychiatrist undertakes training in psychoanalysis, he manifests an intent to acquire a specialty, not to …
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Washington Law Review
Liquidations and reincorporations have been utilized in attempts to bail out corporate earnings and profits at capital gains rates. The success of these attempts has been limited by judicial extension of the corporate reorganization sections of the Internal Revenue Code. Professor Hjorth suggests that specific Congressional amendment of section 331 to encompass the liquidation reincorporation problem is preferable to extension of the reorganization provisions which occurred in the recent case of Davant v. Commissioner.
The Capital Nature Of Educational Expenses, Anon
The Capital Nature Of Educational Expenses, Anon
Washington Law Review
Taxpayer, a practicing psychiatrist and part-time teacher of psychiatry, undertook a six year training program in psychoanalysis at the Boston Psychoanalytic Institute. In 1961, he deducted $3,650 paid in fees to the Institute as a business expense under section 162 of the Internal Revenue Code. Although taxpayer contended that the expenses were incurred primarily to maintain or improve skills required in his profession, the Commissioner disallowed the deduction. A sharply divided Tax Court upheld the disallowance, relying on two prior cases holding that when a psychiatrist undertakes training in psychoanalysis, he manifests an intent to acquire a specialty, not to …
Gilmore: Security Interests In Personal Property, Jerry P. Belknap
Gilmore: Security Interests In Personal Property, Jerry P. Belknap
Michigan Law Review
A Review of Security Interests in Personal Property 2 vols. By Grant Gilmore
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Liquidations And Reincorporations—Before And After Davant, Roland L. Hjorth
Washington Law Review
Liquidations and reincorporations have been utilized in attempts to bail out corporate earnings and profits at capital gains rates. The success of these attempts has been limited by judicial extension of the corporate reorganization sections of the Internal Revenue Code. Professor Hjorth suggests that specific Congressional amendment of section 331 to encompass the liquidation reincorporation problem is preferable to extension of the reorganization provisions which occurred in the recent case of Davant v. Commissioner.
Security Aspects Of The Abc Transaction, John T. Schmidt
Security Aspects Of The Abc Transaction, John T. Schmidt
Michigan Law Review
In recent years, investments in subterraneous oil and gas have become a common addition to the investment portfolios of national financial institutions. Relying on the assurances of reputable geological studies, traditionally conservative financers have invested amounts ranging up to several hundred million dollars against collateral once accepted only by speculators and a few adventurous oil-country bankers. The increased interest in these investments is in part attributable to the development of the ABC method of financing the purchase of producing oil and gas properties. This method offers unique tax advantages, which have been discussed elsewhere, but also creates problems for the …
Tax Legislation Of 1966, John E. Donaldson
Tax Legislation Of 1966, John E. Donaldson
William & Mary Law Review
No abstract provided.
Unreasonable Accumulation Of Income By Foundations, Joel H. Feld
Unreasonable Accumulation Of Income By Foundations, Joel H. Feld
Cleveland State Law Review
Unreasonable accumulation of income was and still is one of the the common abuses found in some foundations. Prior to 1950 the Internal Revenue Service challenged foundation exemption by stating that unreasonable accumulations of income were evidence that the foundation was not organized for, or carrying out, a charitable purpose. The courts were reluctant to follow this theory, and gave the law a liberal interpretation in favor of the foundations. It was not until 1950 that Congress enacted Section 3814 of the Internal Revenue Code of 1939. The law is the same today in the Internal Revenue Code of 1954, …
The Bootstrap Loophole: Can It Be Closed, Frank C. Fogl Jr.
The Bootstrap Loophole: Can It Be Closed, Frank C. Fogl Jr.
Cleveland State Law Review
The puropse of this paper is to review the history and background of bootstrap transactions and to determine: (1) Whether there is a need to close the bootstrap loophole; (2) If so, why this loophole has not been closed in the past; (3) Whether the Internal Revenue Code as it now exists contains provisions, if used, that can close this loophole; (4) If new legislation would be required to reach this end. A few key cases will be reviewed and analyzed, with major emphasis placed on the recent Clay Brown' decision, to show the attitude toward bootstrap transactions of both …
Book Review, James T. Flaherty
Book Review, James T. Flaherty
Cleveland State Law Review
Reviewing Weston Vernor Jr., Lillian M. Vernor and James F. Walom, Federal Income Taxation of Individuals, Jooint Committee on Continuing Legal Education, 1967