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Articles 1 - 13 of 13
Full-Text Articles in Law
The Expanding Rights Of Third Parties Under The Internal Revenue Service's Tax Preparers Project: A Limit On Internal Revenue Fishing Expeditions., Gregory A. Mazza
The Expanding Rights Of Third Parties Under The Internal Revenue Service's Tax Preparers Project: A Limit On Internal Revenue Fishing Expeditions., Gregory A. Mazza
St. Mary's Law Journal
Abstract Forthcoming.
Treatment Of Income Tax Refunds In Bankruptcy After Lines V. Frederick, Michigan Law Review
Treatment Of Income Tax Refunds In Bankruptcy After Lines V. Frederick, Michigan Law Review
Michigan Law Review
Under section 70a(5) of the Bankruptcy Act, the bankruptcy trustee is entitled to take the debtor's interest in "property" that "prior to the filing of the petition [the debtor] could by any means have transferred or which might have been levied upon and sold under judicial process against him." The Act does not, however, specifically define the term "property," and, as a result, the Supreme Court has developed its own definition. No problem has been presented by money or assets held by the bankrupt at the time of filing; such items are uniformly considered to be property. Nor has a …
The Employee's Home Office Deduction: The Problem Of Duplicate Facilities, Michigan Law Review
The Employee's Home Office Deduction: The Problem Of Duplicate Facilities, Michigan Law Review
Michigan Law Review
The Internal Revenue Code expressly and impliedly allows taxpayers to deduct many business-related expenses that also fill personal needs. However, the deductibility of home office expenses under the general provision for business expenses, section 162 of the Code, has been a frequent subject of litigation. Section 162 requires that the employee establish that the expenses were "ordinary and necessary expenses paid or incurred during the taxable year in carrying on any trade or business." Since it is well established that working for an employer is carrying on a trade or business within the statute, in order to secure a deduction …
Limitation On Artificial Accounting Losses (Lal): Another Assault On The Tax Shelter., Jeffrey Clarke Anderson
Limitation On Artificial Accounting Losses (Lal): Another Assault On The Tax Shelter., Jeffrey Clarke Anderson
St. Mary's Law Journal
Abstract Forthcoming.
Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status
Avoiding The Anti-Injunction Statute In Suits To Enjoin Termination Of Tax-Exempt Status
William & Mary Law Review
No abstract provided.
Income Tax "Loopholes" And Political Rhetoric, Boris I. Bittker
Income Tax "Loopholes" And Political Rhetoric, Boris I. Bittker
Michigan Law Review
When used by newspaper reporters and politicians, the term "tax loophole" is always a pejorative, though the tone of disapproval may be mingled with a dash of admiration for the astute lawyer or accountant who discovered the device. Since condemnation is the predominant tone, it is always assumed that loopholes can be quickly and reliably distinguished from tax provisions that are reasonable and fair. Sometimes, to be sure, it is suggested that the only criterion is self-interest: one man's loophole is another man's relief provision. More frequently, loopholes are said to inure primarily, if not solely, to the benefit of …
Bargain Sales As Taxable To The Controlling But Non-Benefiting Shareholder
Bargain Sales As Taxable To The Controlling But Non-Benefiting Shareholder
Washington and Lee Law Review
No abstract provided.
Self-Incrimination And The Use Of Income Tax Returns In Non- Tax Criminal Prosecutions
Self-Incrimination And The Use Of Income Tax Returns In Non- Tax Criminal Prosecutions
Washington and Lee Law Review
No abstract provided.
The Real Estate Investment Trust: State Tax, Tort, And Contract Liabilities Of The Trust, Trustee, And Shareholder, Michigan Law Review
The Real Estate Investment Trust: State Tax, Tort, And Contract Liabilities Of The Trust, Trustee, And Shareholder, Michigan Law Review
Michigan Law Review
This Comment will attempt to alert potential investors in and trustees of REITs to the full extent of the liabilities that they could suffer for contract debts incurred in the name of the trust and torts committed by trust personnel. Since state tax considerations also play a significant role in investment decisions, the manner in which each state taxes the REIT and its shareholders on income derived from property and business in that state will also be investigated. Finally, a rational path out of the morass created by current state law will be articulated in order to prompt renewed discussion …
Judicial Review Of Treasury Regulations For Taxpaying And Nontaxpaying Citizens, Paul E. Sullivan, Jr.
Judicial Review Of Treasury Regulations For Taxpaying And Nontaxpaying Citizens, Paul E. Sullivan, Jr.
Washington Law Review
This paper explores the possibility of subjecting such an administrative ruling to judicial review initiated either by a taxpayer not benefited by the regulation or by a nontaxpayer. For either party to prevail he must prove that he has standing, that judicial review is available, and that there is a remedy which he can obtain by judicial review
Income Tax—Section 482 Of The Internal Revenue Act: Commissioner's Authority To Allocate Income Is Limited By Taxpayer Legal Disability—Commissioner Of Internal Revenue V. First Security Bank Of Utah, N.A., 405 U.S. 394 (1972), J. P. H.
Washington Law Review
First Security Bank, a wholly owned subsidiary of Holding Company, referred its borrowers to Security Life, a sister subsidiary, for the purpose of obtaining credit insurance. Security Life paid no commissions to First Security, but it did pay substantial dividends to Holding Company. By funneling all of the premium income through Security Life, which qualifed for preferential treatment as a life insurance company, Holding Company enjoyed a substantial tax advantage. The Commissioner of Internal Revenue, acting pursuant to section 482 of the Internal Revenue Code,4 sent notice of deficiencies to First Security based on an allocation to that subsidiary of …
Gift And Leaseback: A Continuing Tax Controversy, Eugene L. Mahoney
Gift And Leaseback: A Continuing Tax Controversy, Eugene L. Mahoney
Loyola University Chicago Law Journal
No abstract provided.
Federal Tax Administration And The Small Taxpayer, L. Hart Wright
Federal Tax Administration And The Small Taxpayer, L. Hart Wright
University of Michigan Journal of Law Reform
The actual or supposed complexity of substantive federal tax law has generated two unresolved administrative by-products of peculiar importance in the case of small taxpayers. In each of these circumstances the Internal Revenue Service (and in one, the Congress) has tended to default on its programmatic responsibility to facilitate payment by small taxpayers of no less and no more than they owe under the tax law. For too long and to too large an extent, these taxpayers, although completely bewildered and devoid of self-confidence in the conduct of their tax affairs, have had to fend for themselves, both at return …