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Articles 1 - 15 of 15
Full-Text Articles in Law
Case And Ruling Comments On The 1964 Federal Tax Cases And Rulings, William P. Oberndorfer
Case And Ruling Comments On The 1964 Federal Tax Cases And Rulings, William P. Oberndorfer
William & Mary Annual Tax Conference
No abstract provided.
Actual Expenses Of Ohio Utility Are Considered In Computing Rates Even Though The Hypothetical Company Technique Is Used-General Tel. Co. V. Public Util. Comm'n, Michigan Law Review
Actual Expenses Of Ohio Utility Are Considered In Computing Rates Even Though The Hypothetical Company Technique Is Used-General Tel. Co. V. Public Util. Comm'n, Michigan Law Review
Michigan Law Review
The Public Utilities Commission of Ohio established rates for plaintiff telephone company. In determining the gross annual revenues to which the company was entitled, the Commission allowed, as an item of expense, 112 thousand dollars less for federal income tax than the company would actually be required to pay during the year in question. The allowance for taxes was calculated by following the so-called "hypothetical company" formula as apparently required by a recent line of Ohio Supreme Court decisions. On direct appeal to the Ohio Supreme Court, held, order reversed, two judges dissenting. The utility company should be allowed …
Purchased Executory Contracts And The Federal Income Tax
Purchased Executory Contracts And The Federal Income Tax
Indiana Law Journal
No abstract provided.
Taxation—Bad Debts: Limitations Of The “Promoter Doctrine”, Ronald B. Felman
Taxation—Bad Debts: Limitations Of The “Promoter Doctrine”, Ronald B. Felman
Buffalo Law Review
No abstract provided.
Taxation-Federal Tax Liens-Section 6321 Of The Internal Revenue Code As Basis For Injunction Binding Assets Of Foreign Branch Of American Bank, Gerald J. Laba
Taxation-Federal Tax Liens-Section 6321 Of The Internal Revenue Code As Basis For Injunction Binding Assets Of Foreign Branch Of American Bank, Gerald J. Laba
Michigan Law Review
The Commissioner of Internal Revenue issued jeopardy assessments against the taxpayer, Omar, S.A., a Uruguayan corporation. To avoid payment, Omar began to liquidate its American-held assets by transferring receipts out of the country. Pursuant to its statutory right, under section 6321 of the Internal Revenue Code of 1954, to impose a lien upon all property of a delinquent taxpayer, the United States brought suit against Omar and various New York banks in the domestic and foreign branches of which Omar's funds were deposited. The district court granted a preliminary injunction restraining certain of the banks from transferring any property whether …
Federal Income Tax-Definition Of Collapsible Corporation, John E. Mogk
Federal Income Tax-Definition Of Collapsible Corporation, John E. Mogk
Michigan Law Review
In 1948 petitioner and several other taxpayers, who had previously been active in constructing homes, formed two corporations to build apartment houses. As a result of decreases in the price of building materials and savings on labor and architectural costs, each corporation was left, after completion of construction, with borrowed funds which exceeded costs of construction. In the year following completion of construction the taxpayers distributed the excess borrowed funds of the two corporations and then sold their stock in each at a substantial profit. Petitioner reported, his receipts from the distribution of the loan funds and the profit on …
Subordination Of Mortgages For Future Advances To Federal Tax Liens
Subordination Of Mortgages For Future Advances To Federal Tax Liens
Washington and Lee Law Review
No abstract provided.
Federal Income Tax-Deductibilty Of Depreciation In Year Of Sale Where Sale Price Exceeds Adjusted Basis Of Asset, Paul A. Rothman
Federal Income Tax-Deductibilty Of Depreciation In Year Of Sale Where Sale Price Exceeds Adjusted Basis Of Asset, Paul A. Rothman
Michigan Law Review
Plaintiff sold all the assets used in its business, in the middle of a fiscal year, at a price in excess of their depreciated cost at the beginning of the year. When plaintiff purchased the assets in question, it intended to use them until they became scrap. The assets were sold as part of a going concern years before plaintiff originally intended to dispose of them. A depreciation deduction claimed in the year of the sale was disallowed. An additional assessment was paid, a claim for refund was denied, and this suit was instituted. Held, judgment for plaintiff. Depreciation …
Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer
Tax Free Income: Compensation In Kind And Quasi-In-Kind, Emeric Fischer
William & Mary Law Review
No abstract provided.
Federal Taxation - Depreciation Of Assets In The Year Of Disposal
Federal Taxation - Depreciation Of Assets In The Year Of Disposal
William & Mary Law Review
No abstract provided.
Internal Revenue Code Summons Enforcement And The Accountant
Internal Revenue Code Summons Enforcement And The Accountant
Duquesne Law Review
An increasingly large number of taxpayers-guilty and innocenthave been faced with tax investigations as the Government seeks to enforce the civil and/or criminal sanctions of the Internal Revenue Code. Tax practioners representing such taxpayers have been confronted with a conflict between the demands of the Internal Revenue Service and his clients' interests. In addition, the extensive use of the administrative subpoena, the most powerful weapon in the Internal Revenue Service's arsenal, augmented by the timidity and genuflections of taxpayers and tax practitioners, and complimented by the broad construction given this weapon by the courts, have established precedents thought of by …
Taxation-Federal Tax Liens- First In Time Determines Priority Between State And Federal General Tax Lien, James B. Goodbody
Taxation-Federal Tax Liens- First In Time Determines Priority Between State And Federal General Tax Lien, James B. Goodbody
Michigan Law Review
The United States brought an action in a federal district court to foreclose a tax lien against a solvent taxpayer. Vermont held a lien against the same taxpayer for unpaid withholding taxes which antedated the federal lien, and was joined as a defendant. The state lien was authorized by a statute drawn practically verbatim from the federal tax lien statute. Thus both liens dated from a refusal to pay assessed taxes on demand, reached all interests in property of whatever nature, and were enforceable either by distraint or civil action. The state claimed priority as first in time. The United …
Tax Exempt Organizations, Edward A. Lebit
Tax Exempt Organizations, Edward A. Lebit
Cleveland State Law Review
Although tax exempt organizations are creatures of the state ,it is under the federal law that they seek exemption from tax. Many unqualified organizations have sought and received this exemption. Many abuses and schemes have arisen, in which even qualified organizations have been made parties. The big question is whether the exemption laws are not clear enough or whether they have been lackadaisically enforced. It is this writer's opinion that the law is adequate, and that strict enforcement of the law is all that is necessary to clear up the tax abuses by non-profit organizations which have taken place since …
Book Review, Lawrence R. Bloomenthal
Book Review, Lawrence R. Bloomenthal
Cleveland State Law Review
Reviewing Philip M. Stern, The Great Treasury Raid, Random House, 1964
Taxation Of Non-Qualified Deferred Compensation Plans, Richard S. Weinberg
Taxation Of Non-Qualified Deferred Compensation Plans, Richard S. Weinberg
Kentucky Law Journal
No abstract provided.