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Articles 61 - 76 of 76
Full-Text Articles in Taxation-Federal
And The Rebuttal, Glenn E. Coven
Redefining Debt: Of Indianapolis Power And Fictitious Interest, Glenn E. Coven
Redefining Debt: Of Indianapolis Power And Fictitious Interest, Glenn E. Coven
Faculty Publications
No abstract provided.
The Art Of Regulation Drafting: Structured Discretionary Justice Under Section 355, John W. Lee
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.
Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven
Congress As Indian-Giver: "Phasing-Out Tax" Allowances Under The Internal Revenue Code Of 1986, Glenn E. Coven
Faculty Publications
No abstract provided.
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
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.
Installment Land Contracts--The National Scene Revisited, Dale A. Whitman, Grant S. Nelson
Installment Land Contracts--The National Scene Revisited, Dale A. Whitman, Grant S. Nelson
Faculty Publications
In 1977 we published an article in this Review that discussed the legal aspects of the installment land contract. The installment contract was then, and continues to be, widely used as a device for seller financing of real estate. In our judgment, and increasingly in the judgment of the courts, that is a mistake. Few situations, if any, would lead an informed lawyer to advise his client to use an installment contract rather than its financing cousin, the note secured by a mortgage or deed of trust. Since the prior article was published, the courts have continued to place impediments …
The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven
The Relevance Of Fresh Investment To The Characterization Of Corporate Distributions And Adjustments, Glenn E. Coven
Faculty Publications
No abstract provided.
The Decline And Fall Of Taxable Income, Glenn E. Coven
The Decline And Fall Of Taxable Income, Glenn E. Coven
Faculty Publications
No abstract provided.
The Alternative Minimum Tax: Proving Again That Two Wrongs Do Not Make A Right, Glenn E. Coven
The Alternative Minimum Tax: Proving Again That Two Wrongs Do Not Make A Right, Glenn E. Coven
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.
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
New Developments In The Taxation Of Real Estate Partnerships, Michael T. Madison
Faculty Publications
No abstract provided.
Constructive Cash Distributions In A Partnership: How And When They Occur, Robert S. Parker Jr., John W. Lee
Constructive Cash Distributions In A Partnership: How And When They Occur, Robert S. Parker Jr., John W. Lee
Faculty Publications
Constructive cash distributions to partners with possible concomitant severe tax impact can occur whenever a partners share of firm or individual liabilities is cut. This reduction of liabilities can be triggered by a variety of typical partnership transactions. Messrs. Parker arid Lee analyze those transactions under which there is the danger of unforeseen taxation and urge extreme caution.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Retroactive Allocations To New Partners: An Analysis Of The Area After Rodman, John W. Lee, Robert S. Parker Jr.
Faculty Publications
In the recent Rodman case, the Tax Court has held that a partner newly admitted near year-end must report his share of the full year's partnership profits. Messrs. Lee and Parker analyze the status of retroactive partnership allocations in view of Rodman, the first decision to expressly sanction retroactive allocations of income (and implicitly of losses) to new partners, and reallocations under Section 704.
Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee
Command Performance: The Tax Treatment Of Employer Mandated Expenses, John W. Lee
Faculty Publications
No abstract provided.
Blockage Valuation In Federal Tax Law, Harrop A. Freeman
Blockage Valuation In Federal Tax Law, Harrop A. Freeman
Faculty Publications
No abstract provided.