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William & Mary Law School

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Articles 91 - 120 of 179

Full-Text Articles in Taxation-Federal

Doping Out The Capitalization Rules After Indopco, John W. Lee Nov 1992

Doping Out The Capitalization Rules After Indopco, John W. Lee

Faculty Publications

In this article, Lee provides guidance for Treasury and the IRS (in their promised clarification of application of INDOPCO). He delineates how to avoid what he perceives as the past pitfalls of capitalization of recurring, insubstantial, or relatively short-lived expenditures with Ito, or inadequate, amortization. The article also sets forth models for (a) amortizing as. a freestanding deferred charge long-lived substantial self-created intangibles such as business expansion costs, including employee training costs, and (b) expensing, or perhaps better, amortizing currently less substantial or regularly recurring, steady state self-created intangibles (such as repairs and advertising, respectively).


Recent Developments In The Income Taxation Of Individuals, Partnerships, Estates, & Trusts, Meade Emory Dec 1991

Recent Developments In The Income Taxation Of Individuals, Partnerships, Estates, & Trusts, Meade Emory

William & Mary Annual Tax Conference

No abstract provided.


And The Rebuttal, Glenn E. Coven Oct 1991

And The Rebuttal, Glenn E. Coven

Faculty Publications

No abstract provided.


Redefining Debt: Of Indianapolis Power And Fictitious Interest, Glenn E. Coven Jan 1991

Redefining Debt: Of Indianapolis Power And Fictitious Interest, Glenn E. Coven

Faculty Publications

No abstract provided.


Living With Passive Losses - A Practival Approach, Richard M. Lipton Dec 1990

Living With Passive Losses - A Practival Approach, Richard M. Lipton

William & Mary Annual Tax Conference

No abstract provided.


Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, David H. Pogue, Richard E. Levine, Todd Wallace Dec 1990

Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, David H. Pogue, Richard E. Levine, Todd Wallace

William & Mary Annual Tax Conference

No abstract provided.


Recent Developments In Federal Income Taxation, Ira B. Shepard Dec 1990

Recent Developments In Federal Income Taxation, Ira B. Shepard

William & Mary Annual Tax Conference

No abstract provided.


Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner Nov 1990

Interest Allocation Rules: The Nightmare Continues, Philip J. Wiesner

William & Mary Annual Tax Conference

No abstract provided.


Chaos In Wonderland: A Review Of The Regulations Issued Under Irc Section 89, Rebecca J. Miller Dec 1989

Chaos In Wonderland: A Review Of The Regulations Issued Under Irc Section 89, Rebecca J. Miller

William & Mary Annual Tax Conference

No abstract provided.


Taxpayer Bill Of Rights, Lawrence B. Gibbs Dec 1989

Taxpayer Bill Of Rights, Lawrence B. Gibbs

William & Mary Annual Tax Conference

No abstract provided.


Tax Aspects Of Divorce And Separation: Alimony, Child Support And Property Transfers, Robert E. Lee Dec 1989

Tax Aspects Of Divorce And Separation: Alimony, Child Support And Property Transfers, Robert E. Lee

William & Mary Annual Tax Conference

No abstract provided.


The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee Aug 1989

The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee

Faculty Publications

This article analyzes the 35-year evolution of the section 355 regulations from the perspectives of the jurisprudential dichotomy between general principles and detailed rules and administrative law theory as to agency discretion.


Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer Feb 1989

Campbell V. Commissioner: The Availability Of Business Expense Or Loss Deductions For Insured Contingencies, Robert B. Lachenauer

William & Mary Law Review

No abstract provided.


Aftermath Of The 1986 Tax Reform Act- Part Ii, Louis H. Diamond Dec 1988

Aftermath Of The 1986 Tax Reform Act- Part Ii, Louis H. Diamond

William & Mary Annual Tax Conference

No abstract provided.


Civil Penalties Under The Internal Revenue Code, L. Paige Marvel Dec 1988

Civil Penalties Under The Internal Revenue Code, L. Paige Marvel

William & Mary Annual Tax Conference

No abstract provided.


Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, Richard E. Levine, David H. Evaul Dec 1988

Passive Activity Losses Under The Internal Revenue Code Of 1986, Richard M. Lipton, Richard E. Levine, David H. Evaul

William & Mary Annual Tax Conference

No abstract provided.


Interest Expense For Noncorporate Taxpayers After The Tax Reform Act Of 1986, Thomas P. Rohman Dec 1987

Interest Expense For Noncorporate Taxpayers After The Tax Reform Act Of 1986, Thomas P. Rohman

William & Mary Annual Tax Conference

No abstract provided.


Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven Jan 1987

Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven

Faculty Publications

No abstract provided.


The Alternative Minimum Tax For Individuals: Outline, Richard E. Fogg Dec 1986

The Alternative Minimum Tax For Individuals: Outline, Richard E. Fogg

William & Mary Annual Tax Conference

No abstract provided.


Individual Income Taxation After The Tax Reform Act Of 1986, Louis A. Mezzullo Dec 1986

Individual Income Taxation After The Tax Reform Act Of 1986, Louis A. Mezzullo

William & Mary Annual Tax Conference

No abstract provided.


Accounting Methods After The Tax Reform Act Of 1986, Howard J. Busbee Dec 1986

Accounting Methods After The Tax Reform Act Of 1986, Howard J. Busbee

William & Mary Annual Tax Conference

No abstract provided.


Capital Gains Exception To The House's "General Utilities" Repeal: Further Indigestions From Overly Processed "Corn Products", John W. Lee Mar 1986

Capital Gains Exception To The House's "General Utilities" Repeal: Further Indigestions From Overly Processed "Corn Products", John W. Lee

Faculty Publications

In this article, Lee first describes the mechanics and tax effects of cost basis corporate acquisitions and analyzes why current tax rules favor such acquisitions over carryover basis acquisition (e .g., tax-free mergers); then he describes the House's proposed repeal in HR 3838 of the General Utilities doctrine in current sections 336-338, focusing on the continued exemption for long-term capital gains of a closely held active business corporation. This sets the stage for analysis of the Corn Products doctrine, which under an "integral asset" reading would deny the exemption to most appreciated operating assets, surely not the intent of the …


Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven Jan 1986

Limiting Losses Attributable To Nonrecourse Debt: A Defense Of The Traditional System Against The At-Risk Concept, Glenn E. Coven

Faculty Publications

No abstract provided.


Personal Financial And Tax Planning With Insurance Products And Comparable Investments, William B. Harman Jr. Dec 1983

Personal Financial And Tax Planning With Insurance Products And Comparable Investments, William B. Harman Jr.

William & Mary Annual Tax Conference

No abstract provided.


Individual And Corporate Planning To Avoid Pitfalls Of Minimum Tax, Oliver C. Murray Dec 1983

Individual And Corporate Planning To Avoid Pitfalls Of Minimum Tax, Oliver C. Murray

William & Mary Annual Tax Conference

No abstract provided.


Cash Or Deferred Arrangements (Section 401(K): Legal Issues And Plan Design, William L. Sollee Dec 1983

Cash Or Deferred Arrangements (Section 401(K): Legal Issues And Plan Design, William L. Sollee

William & Mary Annual Tax Conference

No abstract provided.


The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven Apr 1983

The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven

Faculty Publications

No abstract provided.


Planning With The Changed Cost Recovery Rules, Jere D. Mcgaffey Dec 1981

Planning With The Changed Cost Recovery Rules, Jere D. Mcgaffey

William & Mary Annual Tax Conference

No abstract provided.


The Decline And Fall Of Taxable Income, Glenn E. Coven Jan 1981

The Decline And Fall Of Taxable Income, Glenn E. Coven

Faculty Publications

No abstract provided.


The Installment Sales Revision Act Of 1980, Herbert J. Lerner Dec 1980

The Installment Sales Revision Act Of 1980, Herbert J. Lerner

William & Mary Annual Tax Conference

No abstract provided.