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Articles 751 - 780 of 988
Full-Text Articles in Tax Law
Abstracts, Mary Jane Plumer
Abstracts, Mary Jane Plumer
Michigan Law Review
The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion.
Taxation-Assessment Of Government-Owned Property Leased To Private Enterprise, Allen C. Holmes
Taxation-Assessment Of Government-Owned Property Leased To Private Enterprise, Allen C. Holmes
Michigan Law Review
The Board of Property Assessment, Appeals, and Review of Allegheny County for ad valorem taxes in the state of Pennsylvania increased the assessed value of the realty of the Mesta Machine Company by the sum of $618,000 to include the value of certain additional machinery which had been installed on the premises. The machinery was leased by the United States Government to the company and was placed in the factory in order that the company might manufacture heavy field guns for the Government, under a cost-plus-fixed-fee contract. The legal title and the beneficial ownership of the machinery remained in the …
Taxes And Assessments
Michigan Law Review
Provisions for tax relief for members of the military and naval forces of the United States are found not only in the Soldiers' and Sailors' Relief Act, but also in three other important federal statutes, namely, the Internal Revenue Code, the War Pay and Allotments Act of 1942, and the Current Tax Payment Act of 1943. Relief measures fall into three classes: (1) those granting postponement of taxes and tax proceedings, (2) those providing reduction of the tax burden, and (3) those providing abatement of taxes in the event of death in military service. Those provisions will be discussed in …
Constitutional Law-Right To Impose A License Tax Upon Dissemination Of Religious Literature - Jones V. Opelika Reversed, Michigan Law Review
Constitutional Law-Right To Impose A License Tax Upon Dissemination Of Religious Literature - Jones V. Opelika Reversed, Michigan Law Review
Michigan Law Review
Petitioners were members of the religious sect "Jehovah's Witnesses," who "sold" and/ or donated religious tracts and literature, and in connection therewith used phonographs and records, in their door to door activities to spread their religious beliefs. They failed to obtain a license for the privilege of canvassing and soliciting, as required of all persons by an ordinance of the city of Jeannette, Pennsylvania, and were convicted and fined for violation thereof. Petitions for leave to appeal to the Supreme Court of Pennsylvania were denied; the case came before the United States Supreme Court on petition for writ of certiorari. …
Abstracts, Katherine Kempfer
Abstracts, Katherine Kempfer
Michigan Law Review
The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion.
Taxation - Mistake Of Fact - Restitution - Subrogation, Robert D. Ulrich
Taxation - Mistake Of Fact - Restitution - Subrogation, Robert D. Ulrich
Michigan Law Review
Under the misapprehension of fact that he had an interest in the land, the plaintiff paid the taxes on land belonging to the defendant. The defendant did not know that the plaintiff intended to pay, nor did he promise, subsequent to payment, to reimburse the plaintiff. The action was brought to recover the amount of the payment, and for subrogation to the lien of the state for the taxes. The lower court denied relief; plaintiff appealed. Held, affirmed. Federal Land Bank of Louisville v. Dorman (Ind. App. 1942) 41 N. E. (2d) 661.
Taxation-Capital Stock Tax-What Constitutes "Doing Business", James E. Dunlap
Taxation-Capital Stock Tax-What Constitutes "Doing Business", James E. Dunlap
Michigan Law Review
The capital stock tax is an excise tax levied not on the business itself but on the exercise of the privilege of doing business in a corporate capacity; hence the determination of tax liability involves a decision in each case as to whether the corporation is carrying on or doing business within the meaning of the tax statutes.
Constitutional Law - Criminal Law And Procedure - Presence Of Accused During Arguments Of Law, Arthur B. Lathrop
Constitutional Law - Criminal Law And Procedure - Presence Of Accused During Arguments Of Law, Arthur B. Lathrop
Michigan Law Review
The defendant was indicted for a felony on charges of wilfully attempting to "evade or defeat'' federal income taxes based on his failure to report money allegedly received by him from "backers" of numbers games in exchange for political protection. On cross-examination he was questioned about certain payments made in the year following the ones on which the indictment was based. His attorney objected on the ground that the question was going to be the subject of another indictment against the defendant, and asked that the jury be dismissed while an argument was had upon the point of law raised. …
Abstracts, Katherine Kempfer
Abstracts, Katherine Kempfer
Michigan Law Review
The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion.
Abstracts, Katherine Kempfer
Abstracts, Katherine Kempfer
Michigan Law Review
The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion.
Recent Decisions, Michigan Law Review
Recent Decisions, Michigan Law Review
Michigan Law Review
The recent decisions consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion.
Recent Decisions, Michigan Law Review
Recent Decisions, Michigan Law Review
Michigan Law Review
The abstracts consist merely of summaries of the facts and holdings of recent cases and are distinguished from the notes by the absence of discussion.
Executors And Administrators - Double Domicile - Inheritance Taxation Of Intangibles, Robert Walsh
Executors And Administrators - Double Domicile - Inheritance Taxation Of Intangibles, Robert Walsh
Michigan Law Review
Plaintiff was appointed executor by a Georgia court which found that decedent had been domiciled in Georgia. Defendant was appointed administrator by a New York court which found that decedent was domiciled in New York. Plaintiff and defendant were interpleaded in the Delaware court by a Delaware corporation to determine who was entitled to shares of stock owned by decedent in the Delaware corporation. Plaintiff claimed that the Delaware court was required to give full faith and credit to the Georgia finding that decedent was domiciled in Georgia. The Supreme Court of Delaware found that decedent was domiciled in New …
Criminal Law And Procedure - Statutes-Constitutionality Of Criminal Penalties For Unreasonable Deductions Under Federal Income Tax Statute, William H. Shipley
Criminal Law And Procedure - Statutes-Constitutionality Of Criminal Penalties For Unreasonable Deductions Under Federal Income Tax Statute, William H. Shipley
Michigan Law Review
Defendant was indicted for attempting to evade the federal tax on the income of a certain corporation for the years 1933 to 1936. In providing for deductions from gross income, the statute permits a reasonable allowance for salaries or other compensation for personal services. The government charged that the defendant was a party to a fraudulent scheme whereby, under the guise of paying commissions for services, which commissions were · deducted from gross income, the corporation distributed profits to its stockholders. The trial court submitted to the jury the issue whether the deduction represented a reasonable allowance for the services …
Taxation - Federal Estate Taxation Of Life Insurance Effect Of Treasury Decision 5032 Amending Articles 25 And 27 Of The Estate Tax Regulations, Lloyd M. Forster
Taxation - Federal Estate Taxation Of Life Insurance Effect Of Treasury Decision 5032 Amending Articles 25 And 27 Of The Estate Tax Regulations, Lloyd M. Forster
Michigan Law Review
Stated briefly, the effect of T. D. 5032 has thus been to revert to the original test of payment of premiums for determining when insurance has been "taken out" by the decedent, and to abandon ownership of the policy as a basis for including the proceeds in decedent's estate, thereby departing from the fundamental theory of estate taxation. Thus the regulations, in closing one door to tax avoidance, apparently open another. While this avenue of escape may be narrowed by judicial interpretation, a change in the regulations probably will be required to seal it completely.
Constitutional Law - Due Process - Jurisdiction Of A State To Tax The Exercise Of A Power Of Appointment, Charles J. O'Laughlin
Constitutional Law - Due Process - Jurisdiction Of A State To Tax The Exercise Of A Power Of Appointment, Charles J. O'Laughlin
Michigan Law Review
Decedent's father, a resident of Massachusetts, by his last will created a trust of the residue of his estate, consisting of intangibles, and gave one share to decedent for life, with remainder to whomsoever decedent should appoint by will. The trust was administered in Massachusetts and there was no question as to that state's power to tax. Decedent, a resident of New York, appointed his share to his widow. The New York courts held that although the interest of the decedent fell within the provisions of the New York tax law imposing a tax upon the transfer of the net …
Taxation - Excise Taxes - Meaning Of Dues Or Membership Fees Under The Fereral Revenue Acts, William H. Shipley
Taxation - Excise Taxes - Meaning Of Dues Or Membership Fees Under The Fereral Revenue Acts, William H. Shipley
Michigan Law Review
The Winchester Country Club's by-laws provided for "annual dues" of fifty dollars which entitled the member to all the privileges of the club except golf. By paying fifty dollars more for "full privileges," members obtained the privilege of playing golf for a year. The club's practice was to bill members annually in advance, measured by the privileges previously held. If after such billing a member indicated that he did not want the golf privilege, no attempt was made to collect the charge. The federal government collected taxes on payments to the club for golf privileges on the ground that the …
Taxation Of Annuity Contracts Under Federal Income Tax, Robert Meisenholder
Taxation Of Annuity Contracts Under Federal Income Tax, Robert Meisenholder
Michigan Law Review
A number of questions dealing with the taxability of commercial annuity policies under death tax statutes have received judicial consideration. By contrast, only a few questions dealing with the taxability of these contracts under income tax laws have been raised before the courts. But the income tax problems are equally important in terms of tax liability. Moreover, they will in the future assume an even larger significance in view of the large number of annuity contracts of various types which have been issued and are now being offered by insurance companies. Accordingly some explanation of these problems is warranted.
Taxation - Federal Income Tax - Constructive Receipt Of Income By Lessor Corporation When Rents Paid Directly To Lessor's Stockholders, William H. Shipley
Taxation - Federal Income Tax - Constructive Receipt Of Income By Lessor Corporation When Rents Paid Directly To Lessor's Stockholders, William H. Shipley
Michigan Law Review
In 1864 the Joliet and Chicago Railroad Company made a perpetual lease without a defeasance clause of all of its property to another railroad company. Under the state law, the lease was a conveyance in fee. The lessee agreed to pay as rental an annual dividend of seven dollars a share on the then outstanding stock of the lessor, these payments to be made directly to the shareholders. The dividends paid by the lessee for the years 1931 to 1934 were taxed as income to the lessor, who now sues to recover the tax. Held, payments to the lessor's …
The Present Status Of Multiple Taxation Of Intangible Property, Robert C. Brown
The Present Status Of Multiple Taxation Of Intangible Property, Robert C. Brown
Michigan Law Review
The decision by the Supreme Court in 1932 of the case of First National Bank of Boston v. Maine represented the culmination of a fairly brief but apparently decisive effort by that Court substantially to do away with the taxation of intangible property by more than one state. Successive decisions within the three years previous had sought to do away with such taxation of debts ( no matter how evidenced) by more than one state; and First National Bank v. Maine laid down the same rule for corporate stock.
Federal Estate And Gift Taxation: A Review, Paul G. Kauper
Federal Estate And Gift Taxation: A Review, Paul G. Kauper
Michigan Law Review
Today's tax-encumbered citizen is not only aware that death and taxes are certain but also realizes that they walk hand-in-hand. At the most he may experience a sense of nostalgic grief over Pliny the Younger's argument that an inheritance tax "is an 'unnatural' tax, since it augments the grief and sorrow of the bereaved." He knows that as a matter of history Pliny's argument, however touching and delicate, has not deterred ways and means committees, intent on meeting revenue needs.
Taxation - Income Tax - A Fixed Investment Trust As A Taxable Association, Harry M. Nayer
Taxation - Income Tax - A Fixed Investment Trust As A Taxable Association, Harry M. Nayer
Michigan Law Review
Bonds of a prescribed kind were deposited in an investment trust with defendant, who issued certificates representing equal undivided interests in the trust corpus. Additional interests were created by the deposit of eligible bonds and sufficient cash to make up the current value of an interest, and all such bonds and cash were commingled. The depositor was not confined in making up the new units to the same kinds of bonds that were used in the original units, but could vary them in his discretion. The depositor could order the elimination of unsound bonds by sale, and the proceeds of …
Taxation - Income Tax - Exemption Of Proceeds Of Insurance Policies Payable In The Form Of An Annuity, Wilbur Jacobs
Taxation - Income Tax - Exemption Of Proceeds Of Insurance Policies Payable In The Form Of An Annuity, Wilbur Jacobs
Michigan Law Review
Plaintiff was the beneficiary of a life insurance policy payable in equal installments over a period of twenty years. The deferred payments had been substituted for payment of the face amount of the policy through an option in the policy exercised by the insured a short time before his death. The Commissioner of Internal Revenue included in gross income the amount by which each payment exceeded one-twentieth of the face amount of the policy on the theory that this excess was interest and hence not within the statute exempting insurance from gross income. Plaintiff sued to recover the tax paid. …
United States - Contracts - Effect, When Tax Is Declared Unconstitutional, Of Provisions For Increase Or Decrease Of Purchase Price For Taxes "Imposed" Or "Changed", Wilbur Jacobs
Michigan Law Review
Between May 1935 and January 1936 the federal government purchased flour from respondent through contracts which contained a so-called "up and down" tax clause. The basic price charged included the A.A.A. processing taxes. During this same period respondent obtained an injunction against the collection of said processing taxes and, as a result of the decision of the Supreme Court in United States v. Butler, was relieved of liability for the tax. In a later suit brought by respondent in the Court of Claims to recover on other contracts, the government claimed a setoff for the amount of these taxes. …
Taxation Of Partnership Assets Received By A Deceased Partner And His Estate, Donald H. Treadwell
Taxation Of Partnership Assets Received By A Deceased Partner And His Estate, Donald H. Treadwell
Michigan Law Review
The raising of funds to pay taxes will probably be a major problem of business men for many years to come. Closely rivaling it, however, is the problem of computing the tax. Though the economic definitions of income may be relatively simple, the complex business relationships necessitating equally complex accounting procedures often make the computation of income extremely difficult. This was demonstrated in the recent case of Helvering v. Enright's Estate, a tax case arising out of the death of a law partner. At the time of his death there were three types of assets which had been acquired …
Taxation-- Use Tax--Collection By A Foreign Corporation--Inapplicable Where Foreign Corporation Makes Strictly Interstate Sales, Michigan Law Review
Taxation-- Use Tax--Collection By A Foreign Corporation--Inapplicable Where Foreign Corporation Makes Strictly Interstate Sales, Michigan Law Review
Michigan Law Review
The Michigan Use Tax Act requires every seller of tangible personal property for storage, use or other consumption in the state of Michigan, engaged in the business of selling at retail in Michigan, to collect the tax imposed by the act. Plaintiff is an Illinois corporation operating a merchant tailoring establishment in Chicago. It takes orders in Michigan, from residents, for clothes, fills the orders in Chicago and, by agreement, the title to the clothes is vested in the purchaser upon delivery in Chicago to an interstate carrier. It maintains a branch office in Detroit where samples are kept, salesmen …
Tax Definition Of Reorganization: Mergers And Consolidations, Hugh B. Kuder Jr.
Tax Definition Of Reorganization: Mergers And Consolidations, Hugh B. Kuder Jr.
Michigan Law Review
In connection with income taxation, some importance is attached to the difference between mergers and consolidations. The difference may be of import in deciding whether or not income has been realized. Too, when the resulting corporation files a return, it may be necessary to determine whether it is the product of a merger or of a consolidation.
Constitutional Law-Taxation - Express Immunity Of Federal Instrumentalities, Michigan Law Review
Constitutional Law-Taxation - Express Immunity Of Federal Instrumentalities, Michigan Law Review
Michigan Law Review
A federal land bank filed a complaint against defendant lumber company and the tax commissioner seeking exemption from a state sales tax on purchases of lumber by the bank. The Supreme Court of North Dakota found the bank liable for the tax and on certiorari to the United States Supreme Court it was held, that the Federal Farm Loan Act conferred express immunity from the tax upon the bank and that such Congressional exemption was constitutional by virtue of the "necessary and proper" clause. Federal Land Bank of St. Paul v. Bismarck Lumber Co. (U.S. 1941) 62 S. Ct. …
Taxation - Income Tax - Capital Gains - Cost Basis To Distributee, David N. Mills
Taxation - Income Tax - Capital Gains - Cost Basis To Distributee, David N. Mills
Michigan Law Review
Testator died in 1903, and the executors turned over the residue of his estate to themselves as testamentary trustees in 1905. In 1923, pursuant to the will, trustees delivered part of the original trust property, together with other property purchased with trust funds, to plaintiff, the equitable remainderman under the trust. In 1930 plaintiff sold some of the securities which had constituted the corpus of the trust. In determining the cost basis for the capital gains tax on this transaction, plaintiff claimed that the market value on the date when the trustees delivered the property to him in 1923 should …
Taxation - Insurance Companies - Considerations For Annuity Contracts As "Premiums'' Received For Insurance Contracts, Michigan Law Review
Taxation - Insurance Companies - Considerations For Annuity Contracts As "Premiums'' Received For Insurance Contracts, Michigan Law Review
Michigan Law Review
The defendant commissioner of insurance refused to issue to plaintiff insurance company a certificate of authority to do business in Kansas unless plaintiff paid back taxes claimed to be due on considerations received for "annuity contracts" by the plaintiff, in Kansas, between 1927 and 1938 inclusive. The tax in question was "upon all premiums" received during the year, but the plaintiff contended the word "premiums" did not include considerations received for "annuity contracts." Plaintiff brought mandamus to compel defendant commissioner to issue a certificate of authority to do business. Held, three judges dissenting, that the word "premiums" included considerations …