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Articles 1531 - 1560 of 1669
Full-Text Articles in Tax Law
Limitation On Artificial Accounting Losses (Lal): Another Assault On The Tax Shelter., Jeffrey Clarke Anderson
Limitation On Artificial Accounting Losses (Lal): Another Assault On The Tax Shelter., Jeffrey Clarke Anderson
St. Mary's Law Journal
Abstract Forthcoming.
Another Word On Child Care, Alan L. Feld
Another Word On Child Care, Alan L. Feld
Faculty Scholarship
Professors Schaffer and Berman have written a stimulating brief in support of a deduction for child care expenses in computing federal taxable income. But, in addition, by the range of considerations which their article takes into account, it illustrates the difficulty in opting for deductibility or nondeductibility on the basis of a rational consideration of income tax policies. The difficulty derives primarily from the fact that child care expenditures partake of both a personal (consumption) element and a business (income earning) element.1 To the extent it represents the latter, it does not represent personal income appropriately subject to tax; …
Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee
Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee
Faculty Publications
No abstract provided.
Deductibility Of Expenses For Child Care And Household Services: New Section 214, Alan L. Feld
Deductibility Of Expenses For Child Care And Household Services: New Section 214, Alan L. Feld
Faculty Scholarship
It is increasingly common to find families composed of husband, wife and young children, where both husband and wife are gainfully employed. For some, this pattern is regarded as preferable to the older "ideal" family, where the husband was the sole breadwinner and the wife cared for the children, performed household chores and perhaps engaged in social or charitable activities. Where both spouses are gainfully employed, it is often necessary for the family to employ household help to care for the children and do the housework. These expenditures are "necessary" to the gainful employment of both spouses in the sense …
Corporate Taxation In 1971; Something New, Something Old., Malcolm L. Shaw
Corporate Taxation In 1971; Something New, Something Old., Malcolm L. Shaw
St. Mary's Law Journal
Abstract Forthcoming.
Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee
Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee
University of Richmond Law Review
Employers frequently not only expect but require performance of duties by employees beyond a nine to five tour at the office or plant. Such obligations may include the employee's living or eating on the employer's business premises, relocating himself and his family as a condition precedent to promotion or continued employment, obtaining additional education, entertaining his employer's customers, and traveling, including trips (frequently accompanied by his spouse pursuant to employer command, express or implied) to meetings and conventions, either sponsored by the employer or otherwise.
The Negative Income Tax: An Alternative Solution, William D. Popkin
The Negative Income Tax: An Alternative Solution, William D. Popkin
Articles by Maurer Faculty
No abstract provided.
Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken
Tax Significance Of Payments In Satisfaction Of Liabilities Arising Under Section 16(B) Of The Securities Exchange Act Of 1934, Lawrence Lokken
Scholarly Works
This article examines the income tax significance to the insider of his payment in satisfaction of a liability arising under section 16(b). Such taxpayers have usually sought a deduction against ordinary income in the year of payment. When the issue was first raised, the deduction was denied. Section 16(b) liability was held to be in the nature of a penalty; allowance of the deduction, it was found, "would weaken an effective method of enforcing the sharply defined policy expressed in sectin 16(b)...." In 1961 the Internal Revenue Service modified its earlier position by ruling that section 16(b) is not a …
Personal Vs. Business Expenses: A Comment On Professor Klein's Approach, William D. Popkin
Personal Vs. Business Expenses: A Comment On Professor Klein's Approach, William D. Popkin
Articles by Maurer Faculty
No abstract provided.
Mandatory Buy-Out Agreements For Stock Of Closely Held Corporations, Douglas A. Kahn
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 …
Administration Of A Negative Income Tax, William D. Popkin
Administration Of A Negative Income Tax, William D. Popkin
Articles by Maurer Faculty
No abstract provided.
The Tax Benefit Rule, Claim Of Right Restorations, And Annual Accounting: A Cure For The Inconsistencies, John G. Corlew
The Tax Benefit Rule, Claim Of Right Restorations, And Annual Accounting: A Cure For The Inconsistencies, John G. Corlew
Vanderbilt Law Review
The Internal Revenue Code is premised on an annual accounting concept which requires the taxpayer to count up his transactions at the end of the year and remit to the Government taxes based on the occurrences of that particular year. In theory this requires disregarding the factors of prior or subsequent taxable years, despite the irrelation to events of the tax year in question. In most instances, annual accounting poses no special problem. When applied to certain items whose tax impact transcends more than a single taxable year,however, inconsistencies and inequities may result. Two instances in which inconsistent tax treatment …
Taxation Of The Trust Annuity: The Unitrust Under The Constitution And The Internal Revenue Code, Louis A. Del Cotto, Kenneth F. Joyce
Taxation Of The Trust Annuity: The Unitrust Under The Constitution And The Internal Revenue Code, Louis A. Del Cotto, Kenneth F. Joyce
Journal Articles
No abstract provided.
The Income Taxation Of The Capital Gains Of A Trust, Kenneth F. Joyce
The Income Taxation Of The Capital Gains Of A Trust, Kenneth F. Joyce
Journal Articles
March
Federal Tax Rulings: Procedure And Policy, Saul C. Belz
Federal Tax Rulings: Procedure And Policy, Saul C. Belz
Vanderbilt Law Review
The rulings program of the Internal Revenue Service was designed to meet the need for predictability of the tax consequences of any given financial transaction. Though the rulings program is not particularly important to the average taxpayer, it has become increasingly crucial both to the financial community and to the Service itself. As the tax laws become more complex, and tax risks become increasingly important to the success of business ventures, the need for confirmation before entering into a transaction is intensified. Thus parties to a transaction will generally request a ruling...
"whenever the answer is uncertain or when the …
Income Tax- Corporations-Legal Expenses Incurred In Sale Of Assets Pursuant To A Section 337 Liquidation Are Deductible-United States V. Mountain States Mixed Feed Co., Michigan Law Review
Income Tax- Corporations-Legal Expenses Incurred In Sale Of Assets Pursuant To A Section 337 Liquidation Are Deductible-United States V. Mountain States Mixed Feed Co., Michigan Law Review
Michigan Law Review
In 1961, the stockholders of the Mountain States Mixed Feed Co. voted to liquidate the corporation in such a way as to comply with the requirements of section 337 of the Internal Revenue Code of 1954 (Code). That section provides that if a corporation adopts a plan of complete liquidation, and then within twelve months distributes all its assets, it will not recognize a gain or loss for income tax purposes from the sale or exchange of certain types of property. The corporation sold all of its assets and qualified for non-recognition treatment under section 337. It then claimed a …
Special Treatment Of Cemeteries, David H. Getches
Anticipation Of Income, Paul A. Teschner
Taxation Of Foreign Incorporated Pocketbooks With Nonresident Alien Shareholders, William D. Popkin
Taxation Of Foreign Incorporated Pocketbooks With Nonresident Alien Shareholders, William D. Popkin
Articles by Maurer Faculty
No abstract provided.
Personal Holding Companies And The Revenue Act Of 1964, Jerome B. Libin
Personal Holding Companies And The Revenue Act Of 1964, Jerome B. Libin
Michigan Law Review
By 1964, many years had elapsed since significant changes were made in the federal income tax treatment of so-called "personal holding companies." For that reason alone, any amendments contained in the Revenue Act of 1964 that dealt with personal holding companies would have deserved attention. But the fact is that the changes made by the 1964 Act are so powerful in their thrust that they require the most careful kind of study by every practitioner charged with advising closely held corporations. Since the new provisions are rather complicated in nature, such a study cannot lead to a full understanding of …
Rira -- A Legal Information System In The Internal Revenue Service, David T. Link
Rira -- A Legal Information System In The Internal Revenue Service, David T. Link
Journal Articles
The IRS legal information retrieval program is still in its infancy. The results of its use so far indicate that the program is on a sound foundation. Consequently, the Office has great hopes for it. By eliminating a great deal of the duplication of effort among the attorneys it promises to result in certain economies to the Office. More important, it should assure a more consistent treatment of taxpayers through greater coordination than has ever been possible in the past. And most important, by providing more comprehensive and timely decision-making information the system should further the Offices constant goal of …
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 …
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.
Taxation-Federal Tax Liens--Priority Of Senior Federal Lien Over Local Tax Lien In Mortgage Foreclosure, Samuel J. Mckim Iii
Taxation-Federal Tax Liens--Priority Of Senior Federal Lien Over Local Tax Lien In Mortgage Foreclosure, Samuel J. Mckim Iii
Michigan Law Review
Plaintiff, a first mortgagee, instituted a foreclosure proceeding joining the mortgagors, a second mortgagee, several judgment creditors, and the United States Government. The Government's lien had been recorded subsequently to the first mortgage but had attached prior to the accrual of various local real estate taxes. Plaintiff's motion for summary judgment, that the premises be sold free of the United States lien but subject to all local real property taxes, was granted. After reversal on appeal, the court again granted summary judgment and effected the same distribution, this time by directing that all local real property taxes be paid as …
Taxation-Federal Income Taxation-The Three-Party Sale And Lease-Back, Lawrence R. Velvel S.Ed.
Taxation-Federal Income Taxation-The Three-Party Sale And Lease-Back, Lawrence R. Velvel S.Ed.
Michigan Law Review
The so-called sale and lease-back device has long been the subject of judicial and governmental scrutiny. The Internal Revenue Service has recently decided to begin a more active campaign of enforcement against a certain three-party variation of the sale and lease-back device. The structure of this variation can be best understood by considering the following hypothetical situation.
Taxation--Federal Income Tax--Treatment Of Nondistributable Capital Gains Of Domestic Trust With Foreign Beneficiaries, William C. Brashares
Taxation--Federal Income Tax--Treatment Of Nondistributable Capital Gains Of Domestic Trust With Foreign Beneficiaries, William C. Brashares
Michigan Law Review
Taxpayer, trustee of a domestic inter vivos trust, sued for a refund of United States income taxes paid on nondistributable capital gains of the trust. Trustee claimed that since all the beneficiaries of the trust were United Kingdom residents, this income was tax-exempt under the United States-United Kingdom tax convention provision that a United Kingdom resident "shall be exempt from United States tax on gains from the sale or exchange of capital assets." On appeal by the United States from a district court judgment for the trustee, held, reversed. Although distributable gains are allowed the exemption, long term capital …
Taxation-Federal Income Tax-Enjoining Collection, D. Michael Kratchman S.Ed.
Taxation-Federal Income Tax-Enjoining Collection, D. Michael Kratchman S.Ed.
Michigan Law Review
Taxpayer sued to enjoin collection of federal insurance contributions and unemployment taxes with respect to certain fishermen who worked on boats operated by the corporate taxpayer. The Government contended that under the Internal Revenue Code an injunction could not be sustained on a showing of non-liability. The district court issued the injunction on the grounds that the tax was illegal because no employer-employee relationship in fact existed and that collection of the tax would ruin the corporation financially. The court of appeals affirmed, holding that a taxpayer may enjoin the collection of a federal tax when he shows its illegality …
Taxation-Federal Income Tax- Taxpayer's Dividend To Shareholders Allowable As Amortizable Bond Premium Deduction, H. C. Snyder Jr., S.Ed.
Taxation-Federal Income Tax- Taxpayer's Dividend To Shareholders Allowable As Amortizable Bond Premium Deduction, H. C. Snyder Jr., S.Ed.
Michigan Law Review
In an effort to make an amount distributed to its shareholders tax deductible, taxpayer bought utility bonds which were selling at a large premium and which were callable on thirty days' notice. Taxpayer borrowed an amount equal to the lowest call price, mortgaged the bonds to secure the loan, and paid cash equal to the difference, i.e., the premium in this case. After holding the bonds for thirty days, taxpayer declared a dividend of the bonds and distributed them to its shareholders subject to the indebtedness. The shareholders sold the bonds, paid off the loan from the proceeds, and …
Federal Income Taxation-Accounting Methods-Accounting For Prepayments And Estimated Future Expenses, Jerome M. Salle S.Ed.
Federal Income Taxation-Accounting Methods-Accounting For Prepayments And Estimated Future Expenses, Jerome M. Salle S.Ed.
Michigan Law Review
"It is the essence of any system of taxation that it should produce revenue ascertainable, and payable to the government, at regular intervals." In order to obtain regular periodic revenues from the federal income tax, Congress requires all taxpayers to determine their taxable income annually.
Income may be defined as "value added" as a result of a given economic activity. Logically, the most opportune time to measure income occurs whenever that activity has ended, for at that time the continuous growth or contraction in the attributable value will likewise have ended and the income or loss from the activity will …
Taxation-Federal Income Tax-Worthless Debt Of Corporation Deductible Only As A Nonbusiness Bad Debt By Creditor-Partnership, Larry W. Waggoner
Taxation-Federal Income Tax-Worthless Debt Of Corporation Deductible Only As A Nonbusiness Bad Debt By Creditor-Partnership, Larry W. Waggoner
Michigan Law Review
A partnership formed for the purpose of holding and renting real estate and "such other business and enterprises" as might be agreed upon by the partners loaned 120,000 dollars to a corporation which manufactured liquid hair spray for women. This was the only loan the partnership had made. The controlling shareholder in the debtor-corporation was another corporation of which every shareholder was either a parent or grandparent of the partners. The debtor-corporation was to repay the loan in monthly installments of 3,000 dollars plus interest at the rate of twelve percent on the unpaid balance. When the debt became worthless, …