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Articles 31 - 36 of 36
Full-Text Articles in Taxation-Federal
Tax Accrual Workpapers: Protected By A Limited Privilege?, Patricia D. White
Tax Accrual Workpapers: Protected By A Limited Privilege?, Patricia D. White
Articles
United States of America
v.
Arthur Young & Company and Amerada Hess Corporation
(Docket No. 82-687)
To be argued January 16, 1984
International Tax Evasion And Tax Fraud: Typical Schemes And The Legal Issues Raised By Their Detection And Prosecution, Hugh Spall
University of Miami Inter-American Law Review
No abstract provided.
The Tax Benefit Rule: Recovery Reevaluated, Paul T. Kestenbaum
The Tax Benefit Rule: Recovery Reevaluated, Paul T. Kestenbaum
University of Miami Law Review
The United States Supreme Court has granted certiorari in two cases, Bliss Dairy, Inc. v. United States and Hillsboro National Bank v. Commissioner, to resolve a conflict in the circuits as to whether recovery is necessary for the application of the tax benefit rule. The author argues that the application of the tax benefit rule should not depend on the existence of a recovery, but instead should depend on whether an event occurs that is inconsistent with the assumptions underlying the prior deduction; recovery merely is a manifestation of an inconsistent event.
The Likely Source: An Unexplored Weakness In The Net Worth Method Of Proof, Ian M. Comisky
The Likely Source: An Unexplored Weakness In The Net Worth Method Of Proof, Ian M. Comisky
University of Miami Law Review
The government will often suspect a taxpayer of tax evasion if it discovers that the taxpayer's net worth has increased and that the taxpayer did not report the full amount of the increase as taxable income. If the government can establish a likely source for the increase, a jury will be permitted to infer that the taxpayer derived the increase from currently taxable and unreported income. In this article, the author discusses the origins, development, and varied applications of this "likely source inference." Then, after critically examining the constitutional underpinnings of the inference, the author argues that the inference is …
The Tax Reform Act Of 1975 And The Foreign Tax Area, Richard S. Lehman
The Tax Reform Act Of 1975 And The Foreign Tax Area, Richard S. Lehman
University of Miami Inter-American Law Review
No abstract provided.
U.S. Taxation Of U.S. Real Estate Owned By Nonresident Aliens And Foreign Corporations, Robert B. Alexander Jr.
U.S. Taxation Of U.S. Real Estate Owned By Nonresident Aliens And Foreign Corporations, Robert B. Alexander Jr.
University of Miami Law Review
No abstract provided.