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Articles 1 - 15 of 15

Full-Text Articles in Law

Congressional Sanction Of Illicit Cohabitation- The Tax Reform Act Of 1969, James L. Musselman Nov 1979

Congressional Sanction Of Illicit Cohabitation- The Tax Reform Act Of 1969, James L. Musselman

BYU Law Review

No abstract provided.


Federal Income Tax—Amoritization And The Expansion Sports Franchise—First Northwest Industries Of America, Inc. V. Commissioner, 70 T.C. 817 (1978), Roberta Reiff Katz Oct 1979

Federal Income Tax—Amoritization And The Expansion Sports Franchise—First Northwest Industries Of America, Inc. V. Commissioner, 70 T.C. 817 (1978), Roberta Reiff Katz

Washington Law Review

This note will first discuss past taxation practices of professional sports franchises. It will explain the "mass asset theory" as it has been applied to intangible assets outside the sports context and then examine the conflicting positions of the IRS and the Sonics as to the theory's applicability to the expansion franchise. Next, it will discuss the Tax Court's reasons for deciding not to apply the theory in First Northwest and suggest that the Ninth Circuit should similarly conclude that the theory is inappropriate in the context of expansion franchises. Finally, the note will explain the primary problem ...


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.


Issues In Federal, State, And Tribal Taxation Of Reservation Wealth: A Survey And Economic Critique, Russel Lawrence Barsh Jun 1979

Issues In Federal, State, And Tribal Taxation Of Reservation Wealth: A Survey And Economic Critique, Russel Lawrence Barsh

Washington Law Review

This article will consider the most important Indian tax decisions, comparing the intended results of the decisions in the context of congressional Indian law with their probable economic consequences. Part II briefly reviews the main factors essential for proper economic evaluation of a tax. Part III critically surveys recent law of federal taxation of reservation wealth. Part IV similarly surveys and criticizes decisions regarding state taxation of reservation wealth. Part V offers alternate resolutions for state-Indian taxation disputes. In Part VI, the article proposes a framework for applying tax economics productively to the problem of meeting tribal revenue needs.


Proper Standard For Enforcing An Internal Revenue Service Section 7602 Summons: United States V. Lasalle National Bank, David J. Oliveira May 1979

Proper Standard For Enforcing An Internal Revenue Service Section 7602 Summons: United States V. Lasalle National Bank, David J. Oliveira

Boston College Law Review

No abstract provided.


Reflections On Section 382: Searching For A Rationale, J. Clifton Fleming Jr. May 1979

Reflections On Section 382: Searching For A Rationale, J. Clifton Fleming Jr.

BYU Law Review

No abstract provided.


The Haitian Vacation: The Applicability Of Sham Doctrine To Year-End Divorces, Michigan Law Review May 1979

The Haitian Vacation: The Applicability Of Sham Doctrine To Year-End Divorces, Michigan Law Review

Michigan Law Review

This Note examines the propriety of applying the sham doctrine to tax-motivated divorces. Section I outlines the evolution of the sham doctrine from its exposition in Gregory v. Helvering through its expression in two different tests for commercial transactions. Section II then studies the relationship between state divorce law and the marital status provisions of the Internal Revenue Code to demonstrate the clear congressional preference for incorporating state law by reference rather than creating an independent federal law of marriage. It also examines the history of the 1969 Tax Reform Act in a vain effort to discern a congressional desire ...


Taxation Of Foreign-Earned Income In Kind: Henry Taxpayer Goes To Japan, Carole Silver Adler Apr 1979

Taxation Of Foreign-Earned Income In Kind: Henry Taxpayer Goes To Japan, Carole Silver Adler

Indiana Law Journal

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.


Taxpayers And The Civil Rights Attorney's Fees Awards Act Of 1976, Jeffrey R. Martin Mar 1979

Taxpayers And The Civil Rights Attorney's Fees Awards Act Of 1976, Jeffrey R. Martin

Boston College Law Review

No abstract provided.


Treatment Of Cash Distributions To Shareholders Pursuant To A Corporate Reorganization: Shimberg V. United States, Trenholme J. Griffin Mar 1979

Treatment Of Cash Distributions To Shareholders Pursuant To A Corporate Reorganization: Shimberg V. United States, Trenholme J. Griffin

Boston College Law Review

No abstract provided.


Profits In Subrogation : An Insurer's Claim To Be More Than Indemnified, Jay S. Bybee Mar 1979

Profits In Subrogation : An Insurer's Claim To Be More Than Indemnified, Jay S. Bybee

BYU 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.


Accumulated Earnings Tax And Stock Redemptions - Further Thoughts On The Reasonable Business Needs Test, Michael S. Weiner, Bruce M. Graham Jr. Jan 1979

Accumulated Earnings Tax And Stock Redemptions - Further Thoughts On The Reasonable Business Needs Test, Michael S. Weiner, Bruce M. Graham Jr.

Cleveland State Law Review

Few penalty taxes have been imposed with the frequency of the tax on unreasonable accumulations of corporate earnings and profits. Any corporation "formed or availed of for the purpose of avoiding income tax with respect to its shareholders by permitting earnings and profits to accumulate instead of being divided or distributed" is subject to the tax. However, the tax is not properly imposed where the accumulations are for the reasonable business needs of the corporation. Accordingly, the question of what constitutes reasonable business needs is critical. This article considers one aspect of the reasonable business needs question: Under what circumstances ...


Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976 Jan 1979

Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976

Washington and Lee Law Review

No abstract provided.