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Articles 121 - 124 of 124
Full-Text Articles in Taxation-Federal
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
Taxation Of The Disposition Of Partnership Issues: Time To Repeal I.R.C. Section 736, John A. Lynch Jr.
All Faculty Scholarship
As part of the Internal Revenue Code of 1954 Congress enacted section 736. This section specifies the tax treatment of the various types of payments that a partnership may make to a withdrawing partner. It introduced the concept of a liquidation of a partnership interest by the partnership itself, as opposed to the sale of that interest to an outsider or to the continuing partners. In some instances it provides tax consequences for continuing and withdrawing partners which are different from those attendant to a sale. It was designed to make the law concerning disposition of partnership interests simpler and …
The Artist's Tax Dilemma, Wendy J. Gordon
The Artist's Tax Dilemma, Wendy J. Gordon
Scholarship Chronologically
An artist's first job is to create. Somewhere down the line, most artists find they have a second job, which is to sell. Many artists resist involvement in the second task (with mixed results), yet beyond it the artist encounters a duty even more dreaded: to pay taxes.
Excessive Salaries In A Closely Held Corporation, Donald J. Zinner
Excessive Salaries In A Closely Held Corporation, Donald J. Zinner
Cleveland State Law Review
Excessive salaries paid by a closely held corporation create a constant debate between the "owners" of the entity and the Internal Revenue Service, and with other corporation members. The basic law as to the tax aspects underlying the controversy, in the Internal Revenue Code of 1954, is substantially as follows: The compensation claimed as a deduction must be reasonable in amount, and must be paid purely for services. Distributions of profits under the guise of salaries are not deductible. This crucial issue leads to the question: What does the word reasonable salary mean in the framework of a closely held …
Some Problems In Liquidating Personal Holding Companies, Elliott H. Kajan, Martin C. Spector
Some Problems In Liquidating Personal Holding Companies, Elliott H. Kajan, Martin C. Spector
Cleveland State Law Review
Ordinarily, distributions by a personal holding company qualify for the dividends paid deduction only if they are "dividends" under section 316. However, certain distributions in liquidation may also qualify. These liquidating distributions of a personal holding company are divided into two categories: (1) Distributions to the extent of earnings and profits for the taxable year (computed without regard to capital losses) made in complete liquidation of the corporation occurring within 24 months after the adoption of the plan of liquidation; and (2) distributions in liquidation properly chargeable to earnings and profits accumulated after February 28, 1913.