Law Commons^™

The Federal Tax Enactments Of 1969, James F. Dring

William & Mary Annual Tax Conference

No abstract provided.

1969 Federal Tax Rulings, Don W. Llewellyn

William & Mary Annual Tax Conference

No abstract provided.

The Federal Tax Sharing Idea, John Shannon

William & Mary Annual Tax Conference

No abstract provided.

1969 Leading Federal Tax Cases, John H. Davies

William & Mary Annual Tax Conference

No abstract provided.

Income Tax Deductions For Estate Planning Fees, Stephen E. Gihuley

Vanderbilt Law Review

The need to engage the services of a lawyer may arise in a variety of situations, and the possibility of deducting the fees for a lawyer's services from the client's personal taxable income will ultimately depend on which one of several competing policies of the tax law is properly applicable under the particular circumstances. Taxpayers and their attorneys should be aware of the deductibility of expenses incurred for legal services rendered in connection with the planning of the taxpayer's estate. Such estate planning services include the drafting of a will, the arrangement of inter vivos and testamentary gifts, the creation …

An Evaluation Of Municipal Income Taxation, Joe G. Davis, Jr., Arthur J. Ranson, Iii

Vanderbilt Law Review

In order to delineate the perspective of this Note, two observations must be made. First, the term "municipal income tax" encompasses many variations from city to city in the legal nomenclature used to identify the tax. For example, "wage taxes," "payroll taxes,""earnings taxes," and "occupational license taxes" are widely used terms which simply disguise the presence of a municipal income tax. Secondly, in relation to the traditional municipal property and sales taxes, the municipal income tax is normally supplemental rather than substitutional. An increased utilization of the municipal income tax, however, should partially relieve the burden now imposed on these …

Mandatory Buy-Out Agreements For Stock Of Closely Held Corporations, Douglas A. Kahn

Articles

A buy-out of a shareholder's stock is a sale of his stock holdings in a specific corporation pursuatnt to a pre-existing contract. In recent years such arrangements have, deservedly, become an increasingly popular planning device for shareholders in closely held corporations; they make it possible to limit the class of potential shareholders, provide liquidity for the estate of a deceased shareholder, and establish a value for stock which has no active market. There are two popular categories of buy-out plans. If the prospective purchaser of a decedent's shares is the corporation that issued them, the plan is called an "entity …

Multiple Trusts And Income Tax Avoidance, James H. Oeser

Vanderbilt Law Review

Since the Revenue Act of 1916, the trust has been deemed a separate entity for income taxation purposes. Congress has thus sanctioned the use of the trust as a tax savings device. Under present law, a grantor may place cash or other income producing property in trust, thereby excluding the resulting income from his own tax liability. If the income is currently distributed to the beneficiary, the trust is treated as a conduit, and the beneficiary is taxed in the year of distribution. But where the income is accumulated, the tax is payable by the trust? When this "accumulation trust" …

The Effect Of Revenue Ruling 68-643 On The Prepaid Interest Deduction, William A. Kolibush

West Virginia Law Review

No abstract provided.

Income Tax--Accumulation Of Earnings Tax

West Virginia Law Review

No abstract provided.

Tax Impact Of A Transfer Of A Bad Debt Reserve To A Controlled Corporation: An Analysis Of Schuster V. Commissioner, Edward J. Pulaski Jr.

San Diego Law Review

Max Schuster operated a wholesale business in semi-precious stones in the form of a sole proprietorship. He employed the accrual method of accounting for items of income and expense, and utilized the reserve method of accounting for bad debts for federal income tax purposes. On October 31, 1961, Schuster transferred the assets of his business, including its accounts receivable, to a corporation in a transaction which qualified as a tax-free exchange under section 351 of the Internal Revenue code of 1954. The Commissioner of Internal Revenue disallowed a deduction of $7,432.04 claimed as an addition to the proprietorship's bad debt …

Some Reflections On Trifurcation Of The Government's Handling Of Civil Tax Litigation, Richard C. Pugh

Indiana Law Journal

No abstract provided.

Recent Cases, Law Review Staff

Vanderbilt Law Review

Corporations--Equity--Specific Performance of Stock Option Granted Because of Tax Advantage Feature of Option

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Property--Landlord-Tenant--Rabbinical Court Establishes Far-Reaching Standard of Landlords' Obligations to Tenants

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Taxation--Federal Estate Taxation--Under Treasury Regulation Section 20.2031-8(b), Value of Shares in Mutual Funds Is Public Offering Price on Date of Death Rather Than Redemption Price

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Taxation--Mineral Rights--Carried Interest Loses Deduction for Depletion, Depreciation, and Intangible Drilling Costs During Recoupment

Miranda Warning Held Inapplicable To Tax Fraud Investigations In Absence Of Custodial Atmosphere., G. E. Wilcox Jr.

St. Mary's Law Journal

Abstract Forthcoming.

Armed Services - Taxation - Immunity Of Non-Resident Service Man From The States Sales And Use Tax - United States V. Sullivan, 398 F.2d 672 (2d Cir. 1968), Fred K. Morrison

William & Mary Law Review

No abstract provided.

The Chief Counsel's Policy Regarding Acquiescence And Nonacquiescence In Tax Court Cases, Lester R. Uretz

Indiana Law Journal

No abstract provided.

Income Taxes And The Computation Of Lost Future Earnings In Wrongful Death And Personal Injury Cases - Neff V. United States' Platisv. United States

Maryland Law Review

No abstract provided.

Book Review - Taxation. Comparative Conflict Resolution Procedures In Taxation: Analytic Comparative Study By L. Hart Wright (Et. Al.), William D. Popkin

Articles by Maurer Faculty

No abstract provided.

Taxation Of Nonstatutory Stock Options - A Proposed Answer To A Continuing Problem, Thomas C. Riley

Villanova Law Review

No abstract provided.

Taxation Of Domestically Controlled Foreign Corporations: A Comparative Study Of Subpart F And Section 482, Louis M. Kauder

Villanova Law Review

No abstract provided.

The Liquidation-Reincorporation Device - Analysis And Proposed Solutions, Bruce D. Lombardo, Thomas C. Riley

Villanova Law Review

No abstract provided.

Administration Of A Negative Income Tax, William D. Popkin

Articles by Maurer Faculty

No abstract provided.

The Corporate Professional - United States V. Empey, Hugh Ault, James Smith

Hugh J. Ault

No abstract provided.

The New Mexico Professional Corporation, Hugh Ault, James Smith, Robert Desidero

Hugh J. Ault

No abstract provided.

Professional Corporations - Recent Developments, Hugh Ault

Hugh J. Ault

No abstract provided.