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Full-Text Articles in Taxation-Federal

Taxation - Federal Income Tax - Involuntary Conversion Treatment Afforded Sale Of Remaining Property After Partial Condemnation, Stevan Uzelac Feb 1959

Taxation - Federal Income Tax - Involuntary Conversion Treatment Afforded Sale Of Remaining Property After Partial Condemnation, Stevan Uzelac

Michigan Law Review

Petitioner owned two parcels of real estate across the street from each other which were used as one "economic unit" for purposes of a trucking terminal. One parcel was improved with a terminal building from which trucks would pick up and deliver their shipments, while the other was used as a parking lot for trucks not in use. Petitioner was forced to sell the parking lot under threat of condemnation. Since it was economically unfeasible to operate his business without a nearby parking lot, petitioner subsequently sold the terminal facilities and reinvested the proceeds from the sales of both properties …

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Federal Taxation - Tax Aspects Of Corporate Buy And Sell Agreement, Joel D. Tauber S.Ed. Feb 1959

Federal Taxation - Tax Aspects Of Corporate Buy And Sell Agreement, Joel D. Tauber S.Ed.

Michigan Law Review

It is the purpose of this comment to consider the tax problems connected with both types of "conventional" corporate buy and sell agreements. It should be recognized, however, that there are many questions of local law and business necessity that also exert influence on the use of such agreements.

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The Unwarranted Tax Discrimination Against Creators Of Copyrighted Works And Literary, Musical, Or Artistic Compositions Or Similar Properties, Linza B. Inabnit Jan 1959

The Unwarranted Tax Discrimination Against Creators Of Copyrighted Works And Literary, Musical, Or Artistic Compositions Or Similar Properties, Linza B. Inabnit

Kentucky Law Journal

No abstract provided.

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Income Tax--Liability Of A Life Insurance Beneficiary For Unpaid Income Taxes Of The Insured, John T. Bondurant Jan 1959

Income Tax--Liability Of A Life Insurance Beneficiary For Unpaid Income Taxes Of The Insured, John T. Bondurant

Kentucky Law Journal

No abstract provided.

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State Taxation Of The Net Income From Interstate Business, Harry L. Snead Jr. Jan 1959

State Taxation Of The Net Income From Interstate Business, Harry L. Snead Jr.

University of Richmond Law Review

On February 24, 1959, the Supreme Court of the United States, in companion cases, held, by a 6-3 vote, that a state could levy a properly apportioned tax on the net income of a corporation doing a purely interstate business, provided there were sufficient "activities" within the state to justify a tax. NorthwesternStates PortlandCement Co. v. Minnesota, and Commissioner v. Stockham Valves and Fittings, Inc. Were this article a movie script, I would begin by portraying the separate meetings of two groups: the hastily summoned executive committee of the National Association of Manufacturers gravely, but vigorously, exploring means of avoiding …

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Book Review, Gerald M. Ozan Jan 1959

Book Review, Gerald M. Ozan

Cleveland State Law Review

Reviewing Ernest R. Mortenson, Federal Tax Fraud Law, Bobbs-Merrill Co., 1958

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Puerto Rico - Tax Haven Or Tax Trap, Marvin I. Kelner, Lloyd J. Fingerhut Jan 1959

Puerto Rico - Tax Haven Or Tax Trap, Marvin I. Kelner, Lloyd J. Fingerhut

Cleveland State Law Review

This article does not encompass the entire subject of foreign taxation but is limited to two specific questions involved therein: 1. Where does a sale take place for purposes of Federal Taxation? 2. If it is determined that the sale takes place partly within and partly without the U. S., how much of the income from such sales is taxable to the U. S.?

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Excludability Of Quarters Allowance From Gross Income For Tax Purposes, Herbert Blumberg Jan 1959

Excludability Of Quarters Allowance From Gross Income For Tax Purposes, Herbert Blumberg

Buffalo Law Review

Boykin v. Commissioner of Internal Revenue, .__ F.2d __, CCH 1958 STAND. FED. TAX REP. (58-2 U.S. Tax Cas.) 119900 (8th Cir. Oct. 30, 1958).

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Fellowships Grants Under The Internal Revenue Code Of 1954, Eugene Salisbury Jan 1959

Fellowships Grants Under The Internal Revenue Code Of 1954, Eugene Salisbury

Buffalo Law Review

Wrobleski v. Bingler, 58-2 U.S.T.C. -, 161 Fed. Supp. 901 (1958).

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Taxation Of Fringe Benefits Of Employees, Lawrence R. Bloomenthal Jan 1959

Taxation Of Fringe Benefits Of Employees, Lawrence R. Bloomenthal

Cleveland State Law Review

To attract and hold well-qualified personnel, management is finding it increasingly important to offer numerous "fringe benefits." These may include payment of moving costs, country club memberships, providing temporary living expense allowances and even reimbursement for benefits surrendered upon leaving a previous employer. While of chief importance for officers and executive agents, these benefits are also important to all other employees.

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Federal Taxation - Transferee Liability Of Insurance Beneficiary, John Gelder S.Ed. Dec 1958

Federal Taxation - Transferee Liability Of Insurance Beneficiary, John Gelder S.Ed.

Michigan Law Review

Nearly six years after taxpayer died income tax deficiencies were determined against his estate. Since his estate was insolvent the Commissioner sought to impose transferee liability under section 311 of the 1939 code (now I.R.C. section 6901) on plaintiff, taxpayer's widow, as beneficiary of" her husband's life insurance. The Tax Court, applying federal law, held plaintiff liable for the entire deficiency since the proceeds received by her exceeded that amount. The court of appeals, applying state law, reversed and ruled that the beneficiary was not a "transferee" within the meaning of section 311 even to the extent of the cash …

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Motor Carrier Taxation, Hal H. Hale Oct 1958

Motor Carrier Taxation, Hal H. Hale

Vanderbilt Law Review

Provisions of the Federal Aid Highway Act of 1956 vastly expanded the federal role in highway improvement on a long range basis, especially with respect to the so-called Interstate System. Authorizations of highway aid were further increased substantially by Congress in legislation enacted in 1958. The 1956 act for the first time also provided that the funds to pay for federal aid highway programs should come from specified levies upon highway users and a highway trust fund was established for this purpose. Owing principally to cost increases exceeding the original estimates, it has become apparent since the 1956 act was …

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Tax Consequences Of Subdividing Real Estate Sep 1958

Tax Consequences Of Subdividing Real Estate

Washington and Lee Law Review

No abstract provided.

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Income Tax Deductions From Earnings And Profits Sep 1958

Income Tax Deductions From Earnings And Profits

Washington and Lee Law Review

No abstract provided.

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Taxation - Federal Income Tax - Proceeds From Cancellation Of Contract Treated As Ordinary Income, Jerome B. Libin S.Ed. Jun 1958

Taxation - Federal Income Tax - Proceeds From Cancellation Of Contract Treated As Ordinary Income, Jerome B. Libin S.Ed.

Michigan Law Review

Taxpayer had the exclusive right for a period of ten years to purchase all the coal mined by the operator of certain mines. In 1949 the operator paid taxpayer $500,000 as consideration for the complete acquisition of taxpayer's right and interest in the purchase agreement. Taxpayer reported this sum as a long-term capital gain. The Commissioner claimed that the amount received was ordinary income. The Tax Court upheld taxpayer's contention, indicating that the transaction had resulted in the sale or exchange of a capital asset. On appeal by the Commissioner, held, reversed, one justice dissenting. This transaction was more …

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Bonds - Income Bonds - Rights Of Bondholders And Deductibility Of Interest For Federal Income Tax Purposes, Guy B. Maxfield S.Ed., Michael M. Lyons S.Ed. Jun 1958

Bonds - Income Bonds - Rights Of Bondholders And Deductibility Of Interest For Federal Income Tax Purposes, Guy B. Maxfield S.Ed., Michael M. Lyons S.Ed.

Michigan Law Review

An income bond is an obligation of a corporation on which interest is payable only out of earnings, as distinguished from the ordinary corporate bond on which interest is a fixed charge regardless of earnings. Long regarded as a hybrid security which is to be issued only as a last resort, income bonds have grown surprisingly in popularity over the past two decades. It is the purpose of this comment to consider the historical background of income bonds, to make a comparative analysis of the bond indentures as they affect investors' rights, and to consider the deductibility of income bond …

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Taxation - Federal Income Tax - Right Of Donee To Deduct Expense Of Contesting Gift Tax Asserted Against Donor, William J. Wise S.Ed. May 1958

Taxation - Federal Income Tax - Right Of Donee To Deduct Expense Of Contesting Gift Tax Asserted Against Donor, William J. Wise S.Ed.

Michigan Law Review

ln 1948 taxpayer's mother gave him 410 shares of stock in the family enterprise. She filed a gift tax return, but the government, in auditing it, disagreed with her valuation of the stock. Donor had no desire to contest the government's valuation, but since his mother and father still held substantial stock in the business which would eventually go to him, donee desired a lower valuation for estate tax evidentiary purposes. Allegedly fearing personal liability for any deficiency assessed against his mother as well as a lien against the corpus of the gift for any unpaid tax, he decided to …

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The Tax Consequences Of The Sale Of A Patent, George M. Gibson Apr 1958

The Tax Consequences Of The Sale Of A Patent, George M. Gibson

Buffalo Law Review

No abstract provided.

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Continuity Of Business Required For Tax Loss Carryover Mar 1958

Continuity Of Business Required For Tax Loss Carryover

Washington and Lee Law Review

No abstract provided.

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Corporate Debt Financing Under The Tax Law, Jack L. Getman Jan 1958

Corporate Debt Financing Under The Tax Law, Jack L. Getman

Buffalo Law Review

No abstract provided.

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Acute Tax Neuroses, Lawrence Bloomenthal Jan 1958

Acute Tax Neuroses, Lawrence Bloomenthal

Cleveland State Law Review

The major cause of acute taxitis is the mental and physical turmoil arising from accusations by the Revenue Service that false and fraudulent returns have been filed with intent to evade taxes. The three most common means by which tax evasion is discovered are: (1) routine audit-spot checks and surveys; (2) tips from informers in hopes of receiving sizeable rewards,or by jealous neighbors or disgruntled employees; (3) newspaper publicity about marriages, trips, home purchases, robberies, real estate and business transactions.

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A Radical New Income Tax Plan, Donald E. Twitchell Jan 1958

A Radical New Income Tax Plan, Donald E. Twitchell

Cleveland State Law Review

T. Coleman Andrews former Commissioner of Internal Revenue, has embarked upon a campaign to abolish the income tax. J. Bracken Lee, Governor of Utah, has refused to pay part of his income tax as a protest against foreign economic aid. A Constitutional Amendment to limit the income tax to 25% was seriously considered a short time ago. Governor Lee's heroic gesture probably must be dismissed as a defiant skirmish in the perennial protests of isolationists. Though less spectacular, Andrews' views are much more significant because he will gain much sympathy from people who may never consider how they would fare …

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Tax Advantages Of Retirement Plans, Sheldon M. Young, Martin Silverman Jan 1958

Tax Advantages Of Retirement Plans, Sheldon M. Young, Martin Silverman

Cleveland State Law Review

A great many factors have been responsible for the phenomenal growth of retirement plans in the United States since 1930 - not the least of them being the impetus given to the establishment of pension plans as a result of labor negotiations initiated by unions after the Inland Steel decision of1949, wherein the National Labor Relations Board ruled that pensions were a proper subject of collective bargaining. Most authorities, however, recognize that high corporate and personal income tax rates, and broad beneficial tax privileges accorded to recipients of benefits under such programs are largely responsible for the adoption of these …

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Political Campaign Financing: Tax Incentives For Small Contributors, Ellen Ash Peters Jan 1958

Political Campaign Financing: Tax Incentives For Small Contributors, Ellen Ash Peters

Faculty Articles and Papers

No abstract provided.

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Federal Tax Liens, Rex M. Walker Aug 1957

Federal Tax Liens, Rex M. Walker

Washington Law Review

The purpose of this comment is to set out the basic statutory law on which the federal tax lien is founded, to examine the scope of the federal tax lien and its relative priority, and to indicate some of the precautions that can be taken to protect a credit transaction from it.

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Putnam V. Commissioner—The Reimbursable Outlay Under The Tax Law, Ernest J. Brown Apr 1957

Putnam V. Commissioner—The Reimbursable Outlay Under The Tax Law, Ernest J. Brown

Buffalo Law Review

Putnam v. Comm'r, 352 U. S. 82 (1956), affg Putnam v. Comm'r, 224 F. 2d 947 (8th Cir. 1955).

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Taxation - Income Tax - Accurabilty Of Dealer Reserves Withheld By Finance Company, A. Duncan Whitaker S.Ed. Mar 1957

Taxation - Income Tax - Accurabilty Of Dealer Reserves Withheld By Finance Company, A. Duncan Whitaker S.Ed.

Michigan Law Review

Petitioner, a dealer in new and used trailers, had agreements with several finance companies whereby they agreed to buy promissory notes he received on installment sales. The agreements permitted the finance company to withhold a portion of the unpaid balance on each note and credit such amount to the petitioner's "dealer reserve" account. The petitioner was liable for all notes in default and the finance company could charge the reserve with any unpaid balance. The reserve could also be charged with any debts of the petitioner to the company. Periodically, the dealer was to receive portions of the reserve in …

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Income Tax - Non-Business Bad Debt Deduction - Deduction For Partially Secured Bad Debt Deferable Until Liquidation Of Collateral Regardless Of Tax Avoidance Motive, Robert H. Elliott Jr. Feb 1957

Income Tax - Non-Business Bad Debt Deduction - Deduction For Partially Secured Bad Debt Deferable Until Liquidation Of Collateral Regardless Of Tax Avoidance Motive, Robert H. Elliott Jr.

Michigan Law Review

In 1944 the taxpayer liquidated security held for a non-business debt and deducted the balance of the debt as worthless. The creditor had been insolvent for some time. The commissioner disallowed the deduction on the grounds that the taxpayer had held the security after the debt was worthless in order to obtain a larger tax benefit from the deduction. The district court upheld the Commissioner. On appeal, held, reversed. A partially secured debt is not worthless as long as security is available for its satisfaction. The taxpayer's intent is not a factor in determining worthlessness. Loewi v. Ryan, …

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Elections And Discretions Under The Code: The Executor's Dilemma, Byron E. Bronston Jan 1957

Elections And Discretions Under The Code: The Executor's Dilemma, Byron E. Bronston

Articles by Maurer Faculty

No abstract provided.

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Taxation Of Partners And Partnerships Under 1954 Code, W. Lewis Roberts Jan 1957

Taxation Of Partners And Partnerships Under 1954 Code, W. Lewis Roberts

Kentucky Law Journal

No abstract provided.

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