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Articles 1 - 13 of 13
Full-Text Articles in Law
Congressional Sanction Of Illicit Cohabitation- The Tax Reform Act Of 1969, James L. Musselman
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
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 that results …
I.R.C. § 302(B)(1): Dividend Equivalency After United States V. Davis, Ronald L. Nelson
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
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.
Reflections On Section 382: Searching For A Rationale, J. Clifton Fleming Jr.
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
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
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.
Capital Gains And Losses: A Primer (Part Two), Thomas J. Gallagher, Jr.
Florida State University Law Review
No abstract provided.
Profits In Subrogation : An Insurer's Claim To Be More Than Indemnified, Jay S. Bybee
Profits In Subrogation : An Insurer's Claim To Be More Than Indemnified, Jay S. Bybee
BYU Law Review
No abstract provided.
A Source Of Revenue For The Improvement Of Legal Services, Part Ii: A Recommendation For The Use Of Clients' Funds Held By Attorneys In Non-Interest-Bearing Trust Accounts To Support Programs Of The Texas Bar Association And An Analysis Of The Federal Income Tax., Taylor S. Boone
St. Mary's Law Journal
Abstract Forthcoming.
Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.
Capital Gains And Losses: A Primer (Part One), Thomas J. Gallagher, Jr.
Florida State University Law Review
No abstract provided.
Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976
Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976
Washington and Lee 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.
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 …