Taxation-Federal Commons^™

Accumulated Earnings Tax And Stock Redemptions - Further Thoughts On The Reasonable Business Needs Test, Michael S. Weiner, Bruce M. Graham Jr.

Cleveland State Law Review

Few penalty taxes have been imposed with the frequency of the tax on unreasonable accumulations of corporate earnings and profits. Any corporation "formed or availed of for the purpose of avoiding income tax with respect to its shareholders by permitting earnings and profits to accumulate instead of being divided or distributed" is subject to the tax. However, the tax is not properly imposed where the accumulations are for the reasonable business needs of the corporation. Accordingly, the question of what constitutes reasonable business needs is critical. This article considers one aspect of the reasonable business needs question: Under what circumstances …

Taxation Of Homeowners Associations Under The Tax Reform Act Of 1976

Washington and Lee Law Review

No abstract provided.

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.

Inherited Excess Mortgage Property: Death And The Inherited Tax Shelter, Louis A. Del Cotto, Kenneth F. Joyce

Journal Articles

No abstract provided.

Accelerated Depreciation—Tax Expenditure Or Proper Allowance For Measuring Net Income?, Douglas A. Kahn

Articles

Since the 1950s, it has become fashionable to attack various provisions of the Internal Revenue Code by calling them "subsidies" rather than "proper" means of measuring taxable income. These "subsidies" through Code provisions have come to be referred to as "tax expenditures," a term coined by Professor Stanley Surrey in a speech he made as Assistant Secretary of the Treasury for Tax Policy on November 15, 1967. In that speech, Professor Surrey stated that our tax system often deliberately departs "from accepted concepts of net income," so that by granting exemptions, deductions, and credits that are not appropriate to an …

Income Tax Consequences Of Intra-Family Use Of Transfer-Leasebacks, Private Annuities And Installment Sales, Barbara B. Hipple

William & Mary Annual Tax Conference

No abstract provided.

Proposed Legislative Solutions To Tax Shelter Partnership Abuses - The End Of The Aggregate Concept?, Thomas E. Settles

Vanderbilt Law Review

This Note first will set forth the Treasury Department's perception of the present abuses of tax shelter partnerships and will analyze existing procedural rules, the Treasury Department's proposed amendments, and the House of Representatives' proposed amendments in light of these abuses. Next, the Note will examine the substantive law of Subchapter K and will attempt to point out the probable effects of the proposed amendments on the aggregate concept of partnerships, on substantive partnership tax law, and on the viability of the partnership form of business. Finally, this Note will propose a solution to the problem of tax shelter partnership …

Federal Taxation-Reorganizations-Distribution Of Boot To Shareholders Of Merged Corporation Taxable As Dividend, Not Capital Gain-Shim Berg V. United States

BYU Law Review

No abstract provided.

Troubled Real Estate Leasing Companies Trapped Within Personal Holding Company Income Tax Provisions

BYU Law Review

No abstract provided.

Partnerships And The "Used Section 38 Property" Investment Credit: A Widening Loophole, David Brian Mursten

Florida State University 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

Washington and Lee Law Review

No abstract provided.

Tightening The Limitations On Carryovers Under Section 382(B): F Reorganization And The Tax Reform Act Of 1976., J. Pat Tielborg

St. Mary's Law Journal

Abstract Forthcoming.

The Family Estate Trust: Tax Myths And Realities

BYU Law Review

No abstract provided.

Selected Practical Problems With Professional Associations And Professional Corporations., Robert Jorrie, Richard W. Wolf

St. Mary's Law Journal

Abstract Forthcoming.

An Approach To Income Tax Simplification, Fred W. Peel

University of Arkansas at Little Rock Law Review

No abstract provided.

Income And Gift Tax Implications Of Interest-Free Loans Between Relatives

BYU Law Review

No abstract provided.

Federal Income Taxation : A Law Student's Guide To The Leading Cases And Concepts, J. Clifton Fleming

BYU Law Review

No abstract provided.

Federal Tax Law: Where You Divorce Does Make A Difference, Joseph N. Ducanto

Loyola University Chicago Law Journal

No abstract provided.

Home Office Deductions Under The New Section 280a Of The Internal Revenue Code, Edward J. De Guardiola

Florida State University Law Review

No abstract provided.

Hill Farrer & Burrill, 67 T.C. 411 (1976), David Brian Mursten

Florida State University Law Review

Profit Sharing- NEW DEFINITION OF A PARTNERSHIP "PROFITS INTEREST" DISQUALIFIES AN OTHERWISE QUALIFIED PROFIT SHARING PLAN.

Wright V. Commissioner, 62 T.C. 377 (1974), Aff'd, 543 F.2d 593 (7th Cir. 1976), Ruth L. Gokel

Florida State University Law Review

Income Tax- PROPERTY SETTLEMENT IN DIVORCE- AN UNSETTLED AREA OF SETTLED LAW.

Updating The Mccandless Doctrine: Taxing Of Reasonable Compensation Paid By Closely-Held Corporations, 12 J. Marshall J. Prac. & Proc. 113 (1978), John J. Vondran

UIC Law Review

No abstract provided.

The Hidden Tax Trap Of I.R.C. Section 6672, Stephen J. Vasek Jr.

Law Faculty Scholarly Articles

Two recent decisions of the United States Supreme Court examined section 6672 of the Internal Revenue Code. In Slodov v. United States, the Court expressed its views on the personal liability of business managers for unpaid taxes on employee wages. Discharging such liability because of the personal bankruptcy of the business manager was considered in United States v. Sotelo. The focal point of these cases—section 6672 of the Internal Revenue Code—provides for the potential liability of business managers for the employees’ share of taxes on wages (hereinafter trust fund taxes).

Although Slodov and Sotelo are helpful in understanding …

Farm Tax Advantages After The Tax Reform Act Of 1976: Congress Finds The Needle But Misses The Haystack, Daniel A. Minkler

Cleveland State Law Review

This Note will first explain the source and operation of the benefits that may be derived from the utilization of the farm tax rules. Additionally, the ability of taxpayers to use farm losses to offset nonfarm income through sheltered investments will be examined. Next, the Note will review the attempt of Congress to reform the farm tax laws through the Tax Reform Act of 1969, including the attempted elimination of sheltered farm investments. Part III of the Note will explore the mechanics of those provisions of the Tax Reform Act of 19766 which were designed to curtail the use of …

The Affinity Provisions Of The Internal Revenue Code: A Case Study In Nonsimplification, Glenn E. Coven

Faculty Publications

No abstract provided.

Taxation: State Possessory Interest Tax, Patrick E. Powers Jr.

American Indian Law Review

No abstract provided.

Reducing Legal Noise: A Comment On Clark, The Morphogenesis Of Subchapter C: An Essay In Statutory Evolution And Reform, William D. Popkin

Articles by Maurer Faculty

No abstract provided.

Year End Tax Planning - Individuals, Allan S. Rosenbaum

William & Mary Annual Tax Conference

No abstract provided.

Recent Developments Concerning Income Taxation Of Estates And Trusts, Don L. Ricketts

William & Mary Annual Tax Conference

No abstract provided.