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Articles 181 - 210 of 218
Full-Text Articles in Tax Law
Nonrecourse Liabilities And Real Costs: A Reply To Professor Johnson, Erik M. Jensen
Nonrecourse Liabilities And Real Costs: A Reply To Professor Johnson, Erik M. Jensen
Faculty Publications
This article replies to a comment on "The Unanswered Question in Tufts: What Was the Purchaser's Basis?" by Calvin Johnson.
Taxing Corporate Acquisitions: A Proposal For Mandatory Uniform Rules, Glenn E. Coven
Taxing Corporate Acquisitions: A Proposal For Mandatory Uniform Rules, Glenn E. Coven
Faculty Publications
No abstract provided.
Entity Classification And Integration: Publicly Traded Partnerships, Personal Service Corporations And The Tax Legislative Process, John W. Lee
Faculty Publications
No abstract provided.
Tax Court Decision Unsettles Irs Subchapter S Procedures, Glenn E. Coven
Tax Court Decision Unsettles Irs Subchapter S Procedures, Glenn E. Coven
Faculty Publications
No abstract provided.
Subchapter S Distributions And Pseudo Distributions: Proposals For Revising The Defective Blend Of Entity And Conduit Concepts, Glenn E. Coven
Subchapter S Distributions And Pseudo Distributions: Proposals For Revising The Defective Blend Of Entity And Conduit Concepts, Glenn E. Coven
Faculty Publications
No abstract provided.
Contingent Income Items And Cost Basis Corporate Acquisitions: Correlative Adjustments And Clearer Reflection Of Income, John W. Lee, Mark S. Bader
Contingent Income Items And Cost Basis Corporate Acquisitions: Correlative Adjustments And Clearer Reflection Of Income, John W. Lee, Mark S. Bader
Faculty Publications
No abstract provided.
Making Subchapter S Work, Glenn E. Coven
Start-Up Costs, Section 195 And Clear Reflection Of Income: A Tale Of Talismans, Tacked-On Tax Reform And A Touch Of Basics, John W. Lee
Faculty Publications
No abstract provided.
A Policy Analysis Of Fee-Shifting Rules Under The Internal Revenue Code, Gary Myers, Richard L. Schmalbeck
A Policy Analysis Of Fee-Shifting Rules Under The Internal Revenue Code, Gary Myers, Richard L. Schmalbeck
Faculty Publications
Until recently, the costs of litigating federal tax cases were borne exclusively by the parties who incurred them, regardless of whether the government or the taxpayer prevailed in the litigation. This practice reflects the application to tax disputes of the ‘American rule’ against fee shifting. Although the American rule continues to be predominant in the tax area, it has been modified in important respects. An explicit fee-reimbursement rule, benefiting prevailing taxpayers in cases in which the government is found to have acted unreasonably, was added to the Internal Revenue Code (IRC) by the Tax Equity and Fiscal Responsibility Act of …
Book Review Of The Supreme Court And Constitutional Democracy, Neal Devins
Book Review Of The Supreme Court And Constitutional Democracy, Neal Devins
Faculty Publications
No abstract provided.
Bob Jones University V. U.S.: A Political Analysis, Neal Devins
Bob Jones University V. U.S.: A Political Analysis, Neal Devins
Faculty Publications
No abstract provided.
Standing And Adverseness In Challenges Of Tax Exemptions For Discriminatory Public Schools, Thomas Mccoy, Neal Devins
Standing And Adverseness In Challenges Of Tax Exemptions For Discriminatory Public Schools, Thomas Mccoy, Neal Devins
Faculty Publications
No abstract provided.
Who Is Injured When Racially Discriminatory Private Schools Are Tax-Exempt?, Neal Devins
Who Is Injured When Racially Discriminatory Private Schools Are Tax-Exempt?, Neal Devins
Faculty Publications
No abstract provided.
The Subchapter S Revision Act: An Analysis And Appraisal, Glenn E. Coven
The Subchapter S Revision Act: An Analysis And Appraisal, Glenn E. Coven
Faculty Publications
No abstract provided.
Tax Exemptions For Racially Discriminatory Private Schools: A Legislative Proposal, Neal Devins
Tax Exemptions For Racially Discriminatory Private Schools: A Legislative Proposal, Neal Devins
Faculty Publications
In Revenue Ruling 71-447, the Internal Revenue Service expressly denied tax exemptions to racially discriminatory private schools. The Reagan administration recently challenged the existence of a defined policy prohibiting tax exemptions to these schools as well as the propriety of the IRS's involvement in regulating social policy. President Reagan has called upon Congress to settle the issue by enacting affirmative legislation. Congress, however, has maintained that long-established federal policy supports Revenue Ruling 71-447 and has refused to enact affirmative legislation. In this Article, Mr. Devins examines the conflict between the executive, judicial, and legislative branches of government and argues that …
Tax Policy Analysis Of Bob Jones University V. U.S, Charles O. Galvin, Neal Devins
Tax Policy Analysis Of Bob Jones University V. U.S, Charles O. Galvin, Neal Devins
Faculty Publications
No abstract provided.
Capital Expenditures: A Result In Search Of A Rationale, John W. Lee, Nina R. Murphy
Capital Expenditures: A Result In Search Of A Rationale, John W. Lee, Nina R. Murphy
Faculty Publications
No abstract provided.
Partnership Taxation: A Deceased Partner's Final Year, Michelle A. Cecil
Partnership Taxation: A Deceased Partner's Final Year, Michelle A. Cecil
Faculty Publications
One significant and unresolved partnership taxation problem is the taxation of a deceased partner's final year. In a recent case of first impression, Estate of Hesse v. Commissioner, the Tax Court held that the widow of a deceased partner could not include his share of partnership losses incurred during the year of his death on their final joint income tax return. Consequently, the widow lost thousands of dollars in tax refunds because the loss deductions could not offset prior taxable income. The Tax Court believed the result was illogical and unfair, but nevertheless found that the Code required the decedent's …
Liabilities In Excess Of Basis: Focht, Section 357(C)(3) And The Assignment Of Income, Glenn E. Coven
Liabilities In Excess Of Basis: Focht, Section 357(C)(3) And The Assignment Of Income, Glenn E. Coven
Faculty Publications
No abstract provided.
Pre-Retirement Qualified Plan Pay-Outs Under Erisa, Harry V. Lamon, John W. Lee
Pre-Retirement Qualified Plan Pay-Outs Under Erisa, Harry V. Lamon, John W. Lee
Faculty Publications
No abstract provided.
The Affinity Provisions Of The Internal Revenue Code: A Case Study In Nonsimplification, Glenn E. Coven
The Affinity Provisions Of The Internal Revenue Code: A Case Study In Nonsimplification, Glenn E. Coven
Faculty Publications
No abstract provided.
Erisa's "Bad Boy": Forfeiture For Cause In Retirement Plans, John W. Lee
Erisa's "Bad Boy": Forfeiture For Cause In Retirement Plans, John W. Lee
Faculty Publications
No abstract provided.
Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee
Proposed Regs. Under 355 Overhaul Device Test And Single-Business Divisions, John W. Lee
Faculty Publications
Newly issued Proposed Regulations, under Section 355, follow recent decisions allowing horizontal divisions of a single business. In addition, the proposals introduce factors for determining whether a Section 355 transaction is a device for bailing out earnings" Mr. Lee analyzes these and other changes in the Proposed Regulations.
Secs. 465 And 714(D): Invest At Your Own Risk, John W. Lee, Richard E. Fogg
Secs. 465 And 714(D): Invest At Your Own Risk, John W. Lee, Richard E. Fogg
Faculty Publications
No abstract provided.
Credited Service After Erisa, John W. Lee
The "Elaborate Interweaving Of Jurisdiction": Labor And Tax Administration And Enforcement Of Erisa And Beyond, John W. Lee
The "Elaborate Interweaving Of Jurisdiction": Labor And Tax Administration And Enforcement Of Erisa And Beyond, John W. Lee
Faculty Publications
No abstract provided.
Technical And Scientific Evidence In Administrative Adjudication, Scott C. Whitney
Technical And Scientific Evidence In Administrative Adjudication, Scott C. Whitney
Faculty Publications
No abstract provided.
Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee
Section 335 Active Business Management: What Advice To Give Clients Today, John W. Lee
Faculty Publications
The IRS in three Rulings has taken the position that services for the distributing corporation performed through independent contractor could not satisfy the active business requirement test of Section 355. Mr. Lee analyzes the Rulings in light of case law and legislative history that have interpreted the Code's active business test. He concludes that further court tests will be necessary before there can be complete reliance upon active conduct by an independent contractor.
How To Salvage Tax Benefits When A Professional Corporation Disbands, John W. Lee
How To Salvage Tax Benefits When A Professional Corporation Disbands, John W. Lee
Faculty Publications
One of the main concerns of a shareholder in a professional corporation that is dissolving is to protect his interest in the corporation's qualified deferred compensation plan. By use of a case study, Mr. Lee analyzes several methods available for a shareholder to preserve his interest. He also presents a possible solution to other problems arising in connection with the professional corporation's dissolution, such as splitting up the practice (and its accounts receivable) and the status of liquidating distributions if the professionals reincorporate separately.
The "Active Business" Test Of Section 355: Implications Of A Trilogy Of Revenue Rulings, John W. Lee
The "Active Business" Test Of Section 355: Implications Of A Trilogy Of Revenue Rulings, John W. Lee
Faculty Publications
No abstract provided.