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Articles 31 - 60 of 94
Full-Text Articles in Taxation-Federal
Controlling Executive Compensation Through The Tax Code, Gregg D. Polsky
Controlling Executive Compensation Through The Tax Code, Gregg D. Polsky
Washington and Lee Law Review
No abstract provided.
The Employment Tax Challenge To The Check The Box Regulations, Brant J. Hellwig, Gregg D. Polsky
The Employment Tax Challenge To The Check The Box Regulations, Brant J. Hellwig, Gregg D. Polsky
Scholarly Articles
Not available.
The Supreme Court's Casual Use Of The Assignment Of Income Doctrine, Brant J. Hellwig
The Supreme Court's Casual Use Of The Assignment Of Income Doctrine, Brant J. Hellwig
Scholarly Articles
In early 2005, the U.S. Supreme Court answered a question that had been plaguing courts for years: whether plaintiffs should be taxed on the portion of contingent fee awards paid to their attorneys. The Court determined that they should. In this article, Professor Brant J. Hellwig focuses on the analysis employed by the Court to reach its conclusion in Commissioner v. Banks and the implications of that analysis for future cases. Although Professor Hellwig believes that the Court correctly ascertained the plaintiff's tax burden, he suggests that the Court's use of the assignment of income doctrine was both unnecessary to …
Taxing The Promise To Pay, Brant J. Hellwig, Gregg D. Polsky
Taxing The Promise To Pay, Brant J. Hellwig, Gregg D. Polsky
Scholarly Articles
The IRS recently disclosed that it has identified more than 100 executives at 42 leading public corporations that participated in a tax shelter designed to defer the recognition of income from the exercise of stock options. While the agency thus far has identified approximately $700 million in unreported gains from these shelters, it predicts that the revenue loss to the government will ultimately exceed $1 billion. Compared to most tax shelters, this particular transaction (commonly known as the "Executive Compensation Strategy" or "ECS") is remarkably simple. Rather than exercise the options individually, a participating executive instead transfers the options to …
Saving The Family Farm Through Federal Tax Policy: Easier Said Than Done Alex, Alex E. Snyder
Saving The Family Farm Through Federal Tax Policy: Easier Said Than Done Alex, Alex E. Snyder
Washington and Lee Law Review
No abstract provided.
Judicial Activism Is Not The Solution To The Attorney's Fee Problem, Brant J. Hellwig
Judicial Activism Is Not The Solution To The Attorney's Fee Problem, Brant J. Hellwig
Scholarly Articles
The report responds to criticism of the Tax Court's decision in Biehl v. Commissioner, in which the court determined that contingency fees paid to the taxpayer's attorney in employment litigation did not constitute an above-the-line deduction under section 62(a)(2)(A). The report examines the relevant statutes, regulations, and legislative history and concludes that the Tax Court reached the correct decision. Professor Hellwig further contends that had the Tax Court interpreted section 62(a)(2)(A) to grant above-the-line status to the attorney's fees in this case to avoid the disallowance of the miscelleaneous itemized deduction for attorney's fees under the alternative minimum tax, the …
Return To Sharecropping: Lawyers And Clients As Tenants And Landlords In The Tax Treatment Of Contingency Fees, Dean T. Howell
Return To Sharecropping: Lawyers And Clients As Tenants And Landlords In The Tax Treatment Of Contingency Fees, Dean T. Howell
Washington and Lee Law Review
No abstract provided.
What Part Of Rpos Don't You Understand? An Update And Survey Of Standards For Tax Return Positions, J. Timothy Philipps, Michael W. Mumbach, Morgan W. Alley
What Part Of Rpos Don't You Understand? An Update And Survey Of Standards For Tax Return Positions, J. Timothy Philipps, Michael W. Mumbach, Morgan W. Alley
Washington and Lee Law Review
No abstract provided.
Federal Taxation Of Prepaid College Tuition Plans, J. Timothy Philipps
Federal Taxation Of Prepaid College Tuition Plans, J. Timothy Philipps
Washington and Lee Law Review
No abstract provided.
But Reverend, Why Does Your Baptismal Font Have A Diving Board? Equitable Treatment For Vows Of Poverty Under The Federal Income Tax , J. Timothy Philipps
But Reverend, Why Does Your Baptismal Font Have A Diving Board? Equitable Treatment For Vows Of Poverty Under The Federal Income Tax , J. Timothy Philipps
Washington and Lee Law Review
No abstract provided.
Greater Efficiency Or Higher Consumer Rates? Fcc Preemption Of State Depreciation Methods For Telephone Companies In Virginia State Corporation Commission V. Fcc
Washington and Lee Law Review
No abstract provided.
Abusive Tax Shelters After The Tax Reform Act Of 1984
Abusive Tax Shelters After The Tax Reform Act Of 1984
Washington and Lee Law Review
No abstract provided.
Blowing Hot And Cold At The Same Time: Section 1034 Rollover And Rental Deductions On Rental And Sale Of Principal Residence
Washington and Lee Law Review
No abstract provided.
Medically Necessitated Meal And Lodging Costs: Should They Be Deductible Under Internal Revenue Code Section 213?, J. Timothy Philipps, Kenneth B. Tillou
Medically Necessitated Meal And Lodging Costs: Should They Be Deductible Under Internal Revenue Code Section 213?, J. Timothy Philipps, Kenneth B. Tillou
Washington and Lee Law Review
No abstract provided.
Recent Developments Affecting The Income And Gift Tax Consequences Of Interest-Free Loans
Recent Developments Affecting The Income And Gift Tax Consequences Of Interest-Free Loans
Washington and Lee Law Review
No abstract provided.
Tax-Exempt Status Of Amateur Sports Organizations
Tax-Exempt Status Of Amateur Sports Organizations
Washington and Lee Law Review
No abstract provided.
State Taxation Of Nondomiciliary Corporations
State Taxation Of Nondomiciliary Corporations
Washington and Lee Law Review
No abstract provided.
Clarifying The Characteristics Of Brother-Sister Controlled Groups Of Corporations: United States V. Vogel Fertilizer Co.
Washington and Lee Law Review
No abstract provided.
Small Issue Industrial Development Bonds: The Growing Abuse
Small Issue Industrial Development Bonds: The Growing Abuse
Washington and Lee Law Review
No abstract provided.
United States V. Lee, Lewis F. Powell, Jr.
United States V. Lee, Lewis F. Powell, Jr.
Supreme Court Case Files
No abstract provided.
B Reorganizations: The Voting Stock Rule Revisited
B Reorganizations: The Voting Stock Rule Revisited
Washington and Lee Law Review
No abstract provided.
Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976
Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976
Washington and Lee Law Review
No abstract provided.
Are Partnerships Aggregates Or Entities When Determining The Availability Of Investment Credit For Used Property?
Washington and Lee Law Review
No abstract provided.
Bank Credit Cards And The Timing Of Deductions Under Revenue Ruling 78-38: A Return To Consistency
Bank Credit Cards And The Timing Of Deductions Under Revenue Ruling 78-38: A Return To Consistency
Washington and Lee Law Review
No abstract provided.
Incorporating A Cash Basis Business: The Problem Of Section 357©
Incorporating A Cash Basis Business: The Problem Of Section 357©
Washington and Lee Law Review
No abstract provided.
Moe V. Confederated Salish And Kootenai Tribes Of Flathead Reservation, Lewis F. Powell Jr.
Moe V. Confederated Salish And Kootenai Tribes Of Flathead Reservation, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
Fisher V. United States, Lewis F. Powell Jr.
Fisher V. United States, Lewis F. Powell Jr.
Supreme Court Case Files
No abstract provided.
The Home Office Deduction Revisited With A New Test Under Bodzin V. Commissioner
The Home Office Deduction Revisited With A New Test Under Bodzin V. Commissioner
Washington and Lee Law Review
No abstract provided.
Reorganization Of Savings And Loan Associations Under Section 368-A Return To The "Continuity Of Interest" Test
Washington and Lee Law Review
No abstract provided.