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1978

Journal

Tax Law

Institution
Keyword
Publication

Articles 1 - 30 of 31

Full-Text Articles in Law

Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles Nov 1978

Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles

Vanderbilt Law Review

This Note first will set forth the Treasury Department's perception of the present abuses of tax shelter partnerships and will analyze existing procedural rules, the Treasury Department's proposed amendments, and the House of Representatives' proposed amendments in light of these abuses. Next, the Note will examine the substantive law of Subchapter K and will attempt to point out the probable effects of the proposed amendments on the aggregate concept of partnerships, on substantive partnership tax law, and on the viability of the partnership form of business. Finally, this Note will propose a solution to the problem of tax ...


Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten Oct 1978

Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten

Florida State University Law Review

No abstract provided.


Section 243 And Bootstrap Sales: The Dilemma Of The Corporate Shareholder, Don B. Cannada Oct 1978

Section 243 And Bootstrap Sales: The Dilemma Of The Corporate Shareholder, Don B. Cannada

Vanderbilt Law Review

The differences in the tax treatment of dividends and redemptions, the tax goals of individual and corporate shareholders, and the characterizations given corporate distributions by the Internal Revenue Service and the courts have combined to create over-whelming confusion for corporate bootstrap sales. The purpose of this Note is to formulate a rational, consistent approach to the tax treatment of corporate bootstrap sales. Accordingly, this Note initially will discuss various lines of cases governing the possible tax treatment of the seller in a bootstrap acquisition. Special emphasis will be placed on the recent line of cases that deny section 243 intercorporate ...


Challenging The Tax Summons: Procedures And Defenses May 1978

Challenging The Tax Summons: Procedures And Defenses

William & Mary Law Review

No abstract provided.


Standing To Challenge Tax Treatment Of Competitors May 1978

Standing To Challenge Tax Treatment Of Competitors

William & Mary Law Review

No abstract provided.


Comment: The Federal Tax Consequences Of Life Insurance In Estate Planning, John B. Peace Apr 1978

Comment: The Federal Tax Consequences Of Life Insurance In Estate Planning, John B. Peace

University of Arkansas at Little Rock Law Review

No abstract provided.


An Approach To Income Tax Simplification, Fred W. Peel Apr 1978

An Approach To Income Tax Simplification, Fred W. Peel

University of Arkansas at Little Rock Law Review

No abstract provided.


Tax Avoidance, Alan Gunn Apr 1978

Tax Avoidance, Alan Gunn

Michigan Law Review

This Article attempts an almost purely negative criticism. I contend that efforts to explain the results of tax cases not involving penalties by reference to "tax avoidance" are never satisfactory, whether the reference is meant to describe a taxpayer's state of mind or to justify a tax rule by invoking some "need to prevent tax avoidance." Because many tax problems are commonly discussed in terms of "tax avoidance" in one of these senses, and in order to avoid the impression that my arguments would leave the tax law in shambles, I shall suggest some alternative ways of dealing with ...


Challenging The Determination Of Another Taxpayer's Status: The Effect Of Eastern Kentucky V. Welfare Rights Organization, Carla Lowenheim Apr 1978

Challenging The Determination Of Another Taxpayer's Status: The Effect Of Eastern Kentucky V. Welfare Rights Organization, Carla Lowenheim

North Carolina Central Law Review

No abstract provided.


Carrybacks And The (F) Reorganization Mar 1978

Carrybacks And The (F) Reorganization

William & Mary Law Review

No abstract provided.


Recent Cases, Alan W. Duncan, Elton G. Snowden, William A. Holby, Joseph W. Gibbs Mar 1978

Recent Cases, Alan W. Duncan, Elton G. Snowden, William A. Holby, Joseph W. Gibbs

Vanderbilt Law Review

Constitutional Law -- Newsperson's Privilege - The First Amendment Guarantee of a Free Press Protects Against Compelled Disclosure of a Journalist's Exercise of Editorial Control and Judgment

Plaintiff, a former army officer who had achieved national prominence by claiming that his superiors ignored his reports of atrocities by American forces in Vietnam,' brought a libel suit against defendant television producer, reporter, and network for broadcasting a program that cast doubt upon plaintiff's allegations. Contending that defendant did not present available information corroborating plaintiff's claims, plaintiff sought discovery of the producer's beliefs, opinions, intent, and conclusions in preparing ...


Effect Of The 1976 Tax Reform Act On Stock Buy-Out Agreements And Other Close Corporation Plans, Frederic G. Corneel Mar 1978

Effect Of The 1976 Tax Reform Act On Stock Buy-Out Agreements And Other Close Corporation Plans, Frederic G. Corneel

Boston College Law Review

No abstract provided.


Effective Use Of Disclaimers, William Schwartz Mar 1978

Effective Use Of Disclaimers, William Schwartz

Boston College Law Review

No abstract provided.


Xi. Tax Mar 1978

Xi. Tax

Washington and Lee Law Review

No abstract provided.


Foreward: The Interaction Of Tax Planning And Tax Policy, Paul R. Mcdaniel Mar 1978

Foreward: The Interaction Of Tax Planning And Tax Policy, Paul R. Mcdaniel

Boston College Law Review

No abstract provided.


Lump Sum Distributions Under The Tax Reform Act Of 1976, Judith Lidsky Mar 1978

Lump Sum Distributions Under The Tax Reform Act Of 1976, Judith Lidsky

Boston College Law Review

No abstract provided.


Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture Mar 1978

Muni-Funds: Exempt-Interest Dividends And The Feasibility Of Underwriting Fee Recapture

William & Mary Law Review

No abstract provided.


Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten Jan 1978

Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten

Florida State University Law Review

Profit Sharing- NEW DEFINITION OF A PARTNERSHIP "PROFITS INTEREST" DISQUALIFIES AN OTHERWISE QUALIFIED PROFIT SHARING PLAN.


Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel Jan 1978

Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel

Florida State University Law Review

Income Tax- PROPERTY SETTLEMENT IN DIVORCE- AN UNSETTLED AREA OF SETTLED LAW.


Material Participation And The Valuation Of Farm Land For Estate Tax Purposes Under The Tax Reform Act Of 1976, David A. Bratt Jan 1978

Material Participation And The Valuation Of Farm Land For Estate Tax Purposes Under The Tax Reform Act Of 1976, David A. Bratt

Kentucky Law Journal

No abstract provided.


The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek Jan 1978

The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek

Kentucky Law Journal

No abstract provided.


Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola Jan 1978

Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola

Florida State University Law Review

No abstract provided.


Spooner V. Askew, 345 So. 2d 1055 (Fla. 1976), Charles A. Johnson Jan 1978

Spooner V. Askew, 345 So. 2d 1055 (Fla. 1976), Charles A. Johnson

Florida State University Law Review

Ad Valorem Taxation- RATIFICATION OF FLORIDA'S AD VALOREM TAX STRUCTURE: REJECTION OF AN EQUAL PROTECTION CHALLENGE.


Tax Implications Of The Uniform Marriage And Divorce Act: Does The Davis Rule Still Apply In Kentucky?, Susan L. Coleman Jan 1978

Tax Implications Of The Uniform Marriage And Divorce Act: Does The Davis Rule Still Apply In Kentucky?, Susan L. Coleman

Kentucky Law Journal

No abstract provided.


Virginia Wealth Transfer Tax- Proposed Alternatives, Michael D. Flemming Jan 1978

Virginia Wealth Transfer Tax- Proposed Alternatives, Michael D. Flemming

University of Richmond Law Review

House Resolution 34, which was approved by the House of Delegates during the 1977 session of the Virginia General Assembly, observed that Virginia's inheritance and gift tax laws have remained essentially unchanged for more than 50 years and commissioned a study of those laws "in light of recent developments."' The proponents of House Resolution 34 no doubt had the 1976 amendments to the federal estate and gift tax laws fresh on their minds. But in addition to the federal changes, several of the states have altered their approach to transfer taxation in recent years. These changes expand the options ...


Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran Jan 1978

Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran

UIC Law Review

No abstract provided.


The Tax Consequences Of Interest-Free Loans From Corporations To Shareholders And From Employers To Employees, Robert I. Keller Jan 1978

The Tax Consequences Of Interest-Free Loans From Corporations To Shareholders And From Employers To Employees, Robert I. Keller

Boston College Law Review

No abstract provided.


Corporate Taxation - Net Operating Loss Carryovers Do Not Make Otherwise Worhtless Stock Valuable In The Hands Of The Corporate Shareholder, Jennifer Berke Jan 1978

Corporate Taxation - Net Operating Loss Carryovers Do Not Make Otherwise Worhtless Stock Valuable In The Hands Of The Corporate Shareholder, Jennifer Berke

Villanova Law Review

No abstract provided.


Income Shifting Through A Subchapter S Corporation Jan 1978

Income Shifting Through A Subchapter S Corporation

Maryland Law Review

No abstract provided.


State Taxation On The Privilege Of Doing Interstate Business: Complete Auto Transit, Inc. V. Brady, Brandon F. White Jan 1978

State Taxation On The Privilege Of Doing Interstate Business: Complete Auto Transit, Inc. V. Brady, Brandon F. White

Boston College Law Review

No abstract provided.