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Articles 1621 - 1650 of 1666
Full-Text Articles in Taxation-Federal
Judicial Techniques In Combating Tax Avoidance, Ralph S. Rice
Judicial Techniques In Combating Tax Avoidance, Ralph S. Rice
Michigan Law Review
There is no problem today more fundamental in federal tax law than the rationale (or lack of it) that underlies the conduct of the courts in striking down tax avoidance devices and refusing to recognize business arrangements which meet statutory requirements for tax saving but exude an odor piscatorial.
Taxation-Federal Income Tax-Payment To Lessee For Surrender Of Lease Taxable As Capital Gain, Theodore J. St. Antoine
Taxation-Federal Income Tax-Payment To Lessee For Surrender Of Lease Taxable As Capital Gain, Theodore J. St. Antoine
Michigan Law Review
Taxpayer, a tenant in possession of premises under a lease, received a payment from the lessor to vacate and surrender the premises before the lease expired. The Tax Court decided that the payment was taxable only as a capital gain. On appeal, held, affirmed. Since the leasehold interest constituted property, its transfer by the lessee to the lessor was a sale of a capital asset under I.R.C., §117. Commissioner v. Golonsky, (3d Cir. 1952) 200 F. (2d) 72.
Taxation-Collection And Enforcement-Action Against Collector Of Internal Revenue Not The Proper Method Of Removing Federal Tax Liens, John Houck S.Ed.
Taxation-Collection And Enforcement-Action Against Collector Of Internal Revenue Not The Proper Method Of Removing Federal Tax Liens, John Houck S.Ed.
Michigan Law Review
Plaintiff's property was under a federal tax lien. He brought suit in the district court against the Collector of Internal Revenue, alleging fraudulent issuance of the lien and seeking removal and damages occasioned by the cloud on his title. The collector moved to dismiss on the grounds that no claim was stated upon which relief could be granted, and further, that the collector was not the proper party defendant, while the United States, which had not been joined, was indispensable to the proceeding. Held, petition dismissed. The court found no indication of fraud, but even assuming fraud to exist, …
Taxation-Federal Income Tax-Deductibility Of Contributions To Profit-Sharing Trusts, W. H. Bates S.Ed.
Taxation-Federal Income Tax-Deductibility Of Contributions To Profit-Sharing Trusts, W. H. Bates S.Ed.
Michigan Law Review
Plaintiff corporation set up a profit sharing trust for the benefit of its employees as authorized under section 165(a) of the Internal Revenue Code. The plan for the trust, as approved by the Treasury, provided that plaintiff should contribute annually an amount equal to 15 % of net income, as defined, not to exceed 15% of basic salary or wages of all eligible participating employees. For the tax year 1944 plaintiff claimed deductions under section 23(p)(1)(C) for an amount equal to 15% of the total participating payroll, which is actually the allowable maximum, but which in this case exceeded 15% …
Taxation-Federal Income Tax-Exempt Corporations-Statutory Interpretation, Patrick J. Ledwidge
Taxation-Federal Income Tax-Exempt Corporations-Statutory Interpretation, Patrick J. Ledwidge
Michigan Law Review
Plaintiff corporation was organized in 1947 by physicians who had formerly maintained a clinic for the practice of medicine as a partnership. The articles of incorporation provided that there should be no capital stock and no dividends, and stated that plaintiff was organized as a non-profit corporation for the purpose of providing medical treatment and hospitalization to sick and injured persons without regard to ability to pay therefor, and of providing such other incidental charitable services as the "trustees" of the corporation should prescribe. Pursuant to its by-laws, plaintiff paid such annual salaries to its member physicians as the trustees, …
Taxation-Federal Income Tax-Sale Of Goodwill Treated As Sale Of A Capital Asset, David F. Ulmer S.Ed.
Taxation-Federal Income Tax-Sale Of Goodwill Treated As Sale Of A Capital Asset, David F. Ulmer S.Ed.
Michigan Law Review
Plaintiffs were partners in a wholesale produce business which was well established and had a large goodwill value in the area. Plaintiffs sold the whole business, including goodwill, to another produce dealer, with a specific portion of the sale price being allocated to the sale of the goodwill. Included in the sale contract was an agreement by the sellers not to compete with the purchaser for a certain number of years, but it was understood by the parties that none of the sale price was given in consideration of this agreement. Plaintiffs returned the amount received from the sale of …
Commentary On General Relief Under The Excess Profits Tax Act Of 1950, Thomas N. Tarleau
Commentary On General Relief Under The Excess Profits Tax Act Of 1950, Thomas N. Tarleau
Michigan Law Review
Analysis of an excess profits tax involves inquiries which are essentially foreign to the concepts of ordinary income taxation. The question of excess profits arises only after taxable income has been defined and characterized, its recipients determined and the time of receipt established. The problem is to divide taxable income into two components, one representing the corporation's normal profits, which it is permitted to enjoy free of the penalty tax, and the balance which is deemed to be "profits due to the outbreak of hostilities and to large military expenditures." Under the Excess Profits Tax Act of 1950, as was …
A New Seminar In Taxation At The University Of Pennsylvania, Paul W. Bruton, Raymond J. Bradley
A New Seminar In Taxation At The University Of Pennsylvania, Paul W. Bruton, Raymond J. Bradley
Journal of Legal Education
No abstract provided.
Book Reviews, W. Barton Leach, Joe Tussman, Charles O. Gregory, Charles Fahy, John C. O'Byrne Jr., Joseph Curtis, Charles Fairman, Ralph R. Neuhoff, Joseph Hawley Murphy, Charles L. Black Jr., Roscoe L. Barrow, John Hanna
Book Reviews, W. Barton Leach, Joe Tussman, Charles O. Gregory, Charles Fahy, John C. O'Byrne Jr., Joseph Curtis, Charles Fairman, Ralph R. Neuhoff, Joseph Hawley Murphy, Charles L. Black Jr., Roscoe L. Barrow, John Hanna
Journal of Legal Education
No abstract provided.
Taxation--Constitutionality Of Tax-Refund Statute, F. R. T.
Taxation--Constitutionality Of Tax-Refund Statute, F. R. T.
West Virginia Law Review
No abstract provided.
Freedom From Uncertainty In Income Tax Exemptions, Maurice Finkelstein
Freedom From Uncertainty In Income Tax Exemptions, Maurice Finkelstein
Michigan Law Review
Exemptions from obligations to government are as old as Scripture. It is not strange, therefore, that the public interest in humane government should dictate numerous exemptions from the income tax levy, particularly when one considers that the income tax has long ceased to be simply a revenue producing vehicle. The regulation of inflation or deflation, the control of corporate financial structures, the distribution of wealth, all these and many other concern of government have entered into the formula of our income tax laws. The selection of those who are to be benefited by the tax exemption is, of course, made …
Carry-Over And Carry-Back Of Net Operating Loss, W. Lewis Roberts
Carry-Over And Carry-Back Of Net Operating Loss, W. Lewis Roberts
Kentucky Law Journal
No abstract provided.
Stanley And Kilcullen: The Federal Income Tax: A Guide To The Law., Michigan Law Review
Stanley And Kilcullen: The Federal Income Tax: A Guide To The Law., Michigan Law Review
Michigan Law Review
A Review of THE FEDERAL INCOME TAX: A GUIDE TO THE LAW. By Joyce Stanley and Richard Kilcullen.
Tax Practitioners Forum, Michigan Law Review
Tax Practitioners Forum, Michigan Law Review
Michigan Law Review
A Review of TAX PRACTITIONERS FORUM
The Function Of Constitutional Provisions Requiring Uniformity In Taxation: Part I--Introduction And Historical Origins, William L. Matthews Jr.
The Function Of Constitutional Provisions Requiring Uniformity In Taxation: Part I--Introduction And Historical Origins, William L. Matthews Jr.
Kentucky Law Journal
No abstract provided.
Attempts To Avoid Taxes On Corporate Distributions, W. Lewis Roberts
Attempts To Avoid Taxes On Corporate Distributions, W. Lewis Roberts
Kentucky Law Journal
No abstract provided.
Taxation-Federal Income Tax-Claim For Refund-Statute Of Limitations, Samuel N. Greenspoon S.Ed.
Taxation-Federal Income Tax-Claim For Refund-Statute Of Limitations, Samuel N. Greenspoon S.Ed.
Michigan Law Review
The commissioner determined that a deficiency existed in the taxpayer's income tax for 1938. This deficiency assessment was paid in 1941. More than three years later the taxpayer filed a claim for refund which was rejected by the commissioner on the ground that it was barred by the two year limitation period of section 322 (b) (1) of the Internal Revenue Code. The taxpayer then brought suit in the district court contending that the four year limitation period of section 3313 of the code was applicable. The district court sustained the taxpayer, and the judgment was affirmed by the circuit …
Significant Developments In The Law Of Federal Taxation, 1941-1947: Ii, Paul G. Kauper
Significant Developments In The Law Of Federal Taxation, 1941-1947: Ii, Paul G. Kauper
Michigan Law Review
The 1941 Revenue Act carried forward the rather complex normal tax structure prescribed by the 1940 Revenue Act and in addition introduced a corporate surtax rate schedule. The normal tax rates were increased to absorb the 10% defense tax previously imposed as a separate tax and also a very slight increase in the rates applicable to corporations with a normal-tax net income of less than $38,461.54. As so altered the normal tax amounted to 24% in the case of corporations having normal-tax net income over $38,461.54, and in the case of corporations having no more than this amount of normal-tax …
The 1943 Revenue Bill, Randolph E. Paul
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 …
Book Review. Federal Taxation For The Lawyer By Houstin Shockey, Ritchie Gilruth Davis
Book Review. Federal Taxation For The Lawyer By Houstin Shockey, Ritchie Gilruth Davis
Articles by Maurer Faculty
No abstract provided.
Taxation - Federal Income Tax - Exemption Of Life Insurance Proceeds When Paid In The Form Of Annuity, Spencer E. Irons
Taxation - Federal Income Tax - Exemption Of Life Insurance Proceeds When Paid In The Form Of Annuity, Spencer E. Irons
Michigan Law Review
A taxpayer was the beneficiary of life insurance policies which required the insurance company to make fifty annual payments of $2,000 each. At the death of the insured in 1917, the commuted value of this obligation was $53,000. Prior to 1934, the taxpayer had received seventeen payments, aggregating $45,473.40, no part of which had been reported as income. For the year 1934, the taxpayer received $2,581.40, of which $2,000 was the annual payment, and $581.40 was an "excess interest" dividend. He again failed to include any of the amount in his gross income. The commissioner determined that under the Revenue …
Federal Income Tax In Relation To Consumer Cooperatives, Joseph O'Meara
Federal Income Tax In Relation To Consumer Cooperatives, Joseph O'Meara
Journal Articles
The taxation of consumer cooperative associations has proceeded on an erroneous assumption deriving from Eisner v. Macomber. Contrary to that assumption, so long as these non-profit, mutual-benefit undertakings confine themselves to their proper functions they have no income under the Sixteenth Amendment and cannot validly be required to pay an income tax.
Intergovernmental Tax Immunity: Do We Need A Constitutional Amendment?, Robert C. Brown
Intergovernmental Tax Immunity: Do We Need A Constitutional Amendment?, Robert C. Brown
Articles by Maurer Faculty
No abstract provided.
Taxation-Intergovernmental Immunity-Taxation Of The Income Of Federal Employees By A State
Taxation-Intergovernmental Immunity-Taxation Of The Income Of Federal Employees By A State
Indiana Law Journal
No abstract provided.
Some Indicia Of Capital Transfers Under The Federal Income Tax Laws, Paul Harvey
Some Indicia Of Capital Transfers Under The Federal Income Tax Laws, Paul Harvey
Michigan Law Review
The fundamental difference between capital and income is recognized throughout the entire structure of the income tax law, and many decisions have distinguished between the two for the purpose of determining whether a given transaction comes within the meaning of the term "income" as used in the Sixteenth Amendment. But while recognizing the fundamental differences between capital and income, apparently the courts have been somewhat doubtful about advancing any broad, general statements by which specific transactions might be classified. While they have sometimes hesitated to call a specific item a capital transfer, they have, nevertheless, held numerous transactions involving the …
Taxation - Constitutionality Of Federal Admissions Tax As Applied To State Universities, Ralph W. Aigler
Taxation - Constitutionality Of Federal Admissions Tax As Applied To State Universities, Ralph W. Aigler
Michigan Law Review
In declaring invalid the federal tax so far as it applied to admissions to athletic contests conducted under the auspices of the Regents of the University System of Georgia, the United States District Court has added another very interesting case to the many involving immunity from taxation growing out of our dual system of government. The question arose early, and scores of cases have since been decided.
Taxation - Exemption Of State Instrumentality From Federal Tax, Francis T. Goheen
Taxation - Exemption Of State Instrumentality From Federal Tax, Francis T. Goheen
Michigan Law Review
A federal statute provided that "Upon all tobacco and snuff manufactured or imported into the United States, and hereafter sold by the manufacturer or importer, or removed for consumption or sale, there shall be levied, collected, and paid . . . a tax of 18 cents per pound, to be paid by the manufacturer or importer thereof." The company received an order to deliver a quantity of tobacco to a hospital owned by the State of Massachusetts; the company complied by shipping tobacco which had been previously stamped in accordance with the regulations under the above statute. The state paid …
Taxation -Federal Estate Tax-Interpretation Of Loss From "Other Casualty", Virginia M. Renz
Taxation -Federal Estate Tax-Interpretation Of Loss From "Other Casualty", Virginia M. Renz
Michigan Law Review
The Federal Revenue Act provides that losses incurred during settlement of an estate should be deducted when they arise from "fires, storms, shipwreck, or other casualty." Losses to the estate of the testator of the petitioner were caused by Great Britain's going off the gold standard. The petitioners contend this was a casualty within the meaning of the Revenue Act. Held, the language is to be construed according to the rule of ejusdem generis. This casualty is not of the same general kind or class as those specifically mentioned and therefore not within the act. Lyman v. Commissioner of …