Principles of Federal Income Taxation of Individuals

ISBN-10: 0314161465

ISBN-13: 9780314161468

Edition: 7th 2005 (Revised)

List price: $49.00
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Description:

Includes analysis of cases and concepts of the leading casebooks, explanations with amplified diagrams and flow charts, and extensive treatment of the time value of money issues. Explores exotic Wall Street techniques employed to avoid capital gains. In clear language, this book explains equity swaps, shorting against the box, swap funds, and DECS. Presents, among other high-profile situations, a case study of how former Treasury Secretary William Simon and his partners made $700 million in profits on the sale of the Avis car rental agency less than two years after they bought it and paid no taxes.
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Book details

List price: $49.00
Edition: 7th
Copyright year: 2005
Publisher: West Academic
Publication date: 7/26/2005
Binding: Paperback
Pages: 775
Size: 6.00" wide x 9.00" long x 1.00" tall
Weight: 2.222
Language: English

Special Note
Highlights
Table of Illustrations
Introduction
History, Policy and Structure
A Brief History of Income Taxation
In General
The American Income Tax
Theoretical Aspects of Income Taxation
Progressivity, The Marginal Rate of Tax and the Effective Rates of Tax
Alternatives to the Income Tax
Value Added Tax
Net Worth or Wealth Taxes
Head Tax
Consumption or Cash Flow Tax
The "Flat Rate Tax"
Problems With the Income Tax
Allocation of Resources: Imputed Income
Comprehensive Tax Base
Tax Expenditures
Complexity
Recovery of Capital: A Major Theme in the Field
Methods of Recovering Capital
Application to Easements: Inaja Land
Inflation: Kerbaugh-Empire
Other Theoretical Problems
Structure of the Internal Revenue Code
Income in General; Compensation for Services
What Constitutes Income in General: Cesarini, Old Colony Trust, Glenshaw Glass and Drescher
Fringe Benefits
Miscellaneous Benefits Under [section] 132
Meals and Lodging
Group Term Life Insurance
Employee Death Benefits
Accident and Health Benefits
Bargain Purchases of Stock or Other Property and Stock Options
Unrestricted Property
Restricted Property
General Rule
Incentive Stock Options
Section 83
Election
Stock options under [section] 83
How Not to Pay Tax on a Billion Dollars: Deferred Compensation Goes Better With Coke
Other Items of Compensation Income
Tips
Strike Payments
Other Miscellaneous Items of Compensation Income
Other Items of Income and Exclusions from Income
Interest
In General
Tax Exempt Interest
Private Activity Bonds; Qualified Bonds
Original Issue Discount
Background
The 1982 Rules
Dividends and Other Distributions to Stockholders
Rents
In General
Royalties
In General
Advance Royalties: It's Only a Paper Moon
Proceeds From Life Insurance
Annuities
Gifts and Inheritances
Rationale for Excluding
Definition of "Gift": Duberstein
Gifts of Income From Property
Inheritances
In General
Transfers in Trust: Irwin v. Gavit
Prizes, Scholarships and Fellowship Grants
Prizes: McDonell
Scholarships and Fellowship Grants
Discharge of Indebtedness
General Rule and Background: Old Colony Trust; Clark; Kirby Lumber; Zarin
Insolvent or Bankrupt Debtor
Recovery of Damages to the Person or Business
In General
Damages From Personal Injuries
Damages From Injuries to Business; Raytheon
Damages to Capital
Alimony and Similar Payments
Miscellaneous Items of Income and Exclusions From Income
In General
Illegal Income: The Fantastic Saga of Wilcox, Rutkin and James
Income from Dispositions of Property
Overview
The Requirement of a Realization
In General: Macomber, Bruun, Cottage Savings
Marital Property Settlements and Other Satisfactions of Obligations: Davis; Farid-Es-Sultaneh
Computation of Gain or Loss Realized
Amount Realized
Adjusted Basis
Background
Cost Basis
In General
Mortgages and Other Debts of the Purchaser or Seller: Crane
Mortgaging Property Held: Woodsam
The "Footnote 37" Problem: Tufts; Diedrich
Adjustment of the Purchase Price
Bargain Purchases of Property by Shareholders or Employees
Miscellaneous Problems
Carryover Basis
Gifts; Taft
Transfers in Trust
Substituted Basis
Fair Market Value Basis: Property Acquired From a Decedent
Present Rule
Property Acquired From a Decedent: The Saga of Carryover Basis
Property Acquired From a Decedent: The Saga of Carryover Basis continued
Special Rules for Stock, Securities and Mutual Fund Shares
Adjustments to Basis: The Basis as History
Disallowance of Some Losses and Exclusion of Some Gains
In General
Losses From Sales of Residence or Other Personal-Use Property
Losses From Sales of Property in Activities Not Engaged in for Profit
Disallowance of Losses Versus Nonrecognition of Losses
Exclusion of Gain From Sale of Residence
Recognition of Gain or Loss
In General
Tax-Free Exchanges of Business or Investment Property of "Like Kind"
Overview
Mortgages
The Requirement That the Property Be of "Like Kind"
Real Property; Jordan Marsh
Personal Property
The Requirement That the Property Be Held for Productive Use in Trade or Business or for Investment
Three-Cornered Exchanges
Tax-Free Involuntary Conversions (Condemnations, Casualties) Where Proceeds Reinvested
General Rules
Involuntary Conversions of Real Estate
Other Tax-Free Transactions
Wash Sales of Stock or Securities
Losses on Sales and Exchanges Between Related Taxpayers
In general
"Related Taxpayers"; Constructive Ownership Rules
Use of Disallowed Loss by Buyer
Character of Gain or Loss: Capital Gains
The Preferential Treatment of Capital Gains
The Rules for Taxing Capital Gains and Losses
Background
The Mechanics
Capital Gain Rules Under the 1997 Act
Capital Loss Rules
Planning Implications
Holding Appreciated Property Indefinitely
Holding an Appreciated Capital Asset Longer Than Its Required Holding Period
Selling Property That Has Declined in Value
Combined Gains and Losses
Holding Period Problems; Short Sales
Tax Straddles
Definition of Capital Gains and Losses
Statutory and Judicial Rules
Inventory, Property Held Primarily for Sale to Customers
"Corn Products" Assets
Depreciable and Real Property Used in a Trade or Business
Section 1231 Treatment
Copyrights, Literary or Other Artistic Compositions Created by the Taxpayer, Memoranda Held by the Taxpayer and Similar Property
Patents
Recapture of Depreciation
Sale of Depreciable Property to a Related Party
Accounts Receivable
Transfers of Franchises, Trademarks and Trade Names
Cancellation of Lease or Distributor's Agreement
Retirement of Bonds
Worthless Securities
Bad Debts
General Comments on the Sale or Exchange Requirement
Planning Implications: Sale of a Going Business
Policy Aspects of Capital Gains Taxation
Exotic Wall Street Techniques Employed by the Wealthy to Avoid Capital Gains: of ESOP Sales, Upreits, Equity Swaps, Shorting Against the Box, Swap Funds, DECS and the Like: Congressional Response to Some of These Techniques
Assignment of Income: Who is Taxed and the Nature of the Tax
Background
Gratuitous Assignments of Income: Birth of a Metaphor
Assignments of Income for Consideration
Application of Assignment of Income Doctrine
Oil, Gas, and Other Minerals
Leases
Gratuitous Assignments
Assignments for Consideration-Cancellation of the Lease by Landlord or Tenant
Assignments for Consideration-Third Party Transactions
Trusts
Creation of the Trust
Related Topics
How to Pay for Law School (?): Below Interest Loans
Unearned Income of Children
Alimony
Assignment of Income Without Tears
Business Deductions
Structural Issues in General
Putting the Tax Code on the Back of an Envelope
The Deep Structure of the Tax System
The Statutory Structure of the Tax System
Deductions Arising Out of Business and Profit Seeking Activity
Common Business Expenses
Ordinary and Necessary Business Expenses
Travel and Transportation Expenses: Flowers; Hantzis; Andrews; Correll
The Dichotomy Between Deduction and Capital or Personal Expenses
Necessary Rental and Similar Payments; Starr's Estate; Fitzpatrick
Education Expenses
The Law; Hill; Coughlin
The Economics: What Does It Really Cost to Go to Law School?
Expenses for the Production of Income, or for the Maintenance of Investment Property: Higgins; Gilmore; Estate of Baier; Surasky; Myer J. Fleischman; Horrmann; Lowry
Miscellaneous Business and Pleasure Travel Expenses: Rudolph
Entertainment, Amusement and Recreation Expenses: Sutter; Cohan; Sanitary Farms
Limits on Deductibility of Business Meals: Sutter Lives
The Substantiation Requirement for Travel, Entertainment, and Business Gifts
Moving Expenses
Activities Not Engaged in for Profit
Office in the Home; Soliman
Rental of Vacation or Other Homes
Depreciation and Accelerated Cost Recovery
Background
Rationale for Depreciation
Inflation Problems
Basic Methods of Depreciation
The Myth That Accelerated Depreciation Stimulates Investment in Plant and Equipment
"Sinking Fund" Depreciation
The ACRS System; Sharp
Other Business Deductions
Depletion
Intangible Drilling and Development Costs
Bond Premium
Purchased Intangibles: Section 197; Newark Morning Ledger
Miscellaneous Rapid Write-Offs
Alimony and Similar Payments; The Marriage Tax
Alimony and Property Settlements
Property Settlements; Davis
The Marriage Tax: Once More With Feeling
Limitations on Deductions
In General
The Limit of Reasonable Compensation for Services
In General
The Problems of the Double Tax on Corporate Dividends
The Limit of Personal Expenses
Miscellaneous Personal Expenses: Smith
Education Expenses
The Limit of Capital Expenditures: Welch, Mt. Morris Drive-In; Midland Empire; Morton Frank; INDOPCO
The Limit of Public Policy
Background
Illegal Bribes, Kickbacks and Other Payments
Fines and Penalties
Treble Damage Payments Under the Antitrust Laws
Expenses to Influence Legislation and Elections
Other Limits
Expenses and Interest Relating to Tax Exempt Income: Tax Arbitrage
Sham Transactions or Transactions Lacking Economic Substance: Knetsch
Itemized Deductions and Personal Exemptions
Itemized Deductions
In General
Expenses of Tax Advice, Attorneys' Fees, and Litigation
Tax Advice and Litigation
Attorneys' Fees Generally
Interest
Taxes; Cramer
Casualties and Other Losses
Casualties
Other Losses
Bad Debts and Worthless Securities: Whipple
Bad Debts
Worthless Securities
Medical Expenses: Ochs
Charitable Contributions
In General
Percentage Limits
New Rules
Vehicle donations
Noncash Charitable Contributions
Floor on Miscellaneous Itemized Deductions
The Standard Deduction
Personal and Dependency Exemptions
Exemption Amount
Qualifying Child
Alternative Minimum Tax
Tax Planning
Introduction
Tax Shelters
The Building Blocks of Tax Shelters
The "At Risk" Limitations
In General
The Collapse of the Savings & Loan Industry
Passive Activity Losses
In General
Relationship Between the "At Risk" Rules and the Passive Activity Loss Rules
Judicial and Administrative Limitations: Franklin
Corporate Tax Shelters
Other Tax Avoidance Techniques
Corporate Inversion
Corporate Owned Life Insurance
Foreign Credit Cards
Tax Shelters Without Tears
Deferred Payment Sales: Logan
In General
The Installment Method of Reporting
Deferred Compensation: A Survey
In General
Non-Qualified Plans
Current Razzle-Dazzle Executive Compensation Techniques
Incentive Stock Options
Qualified Plans
Festival of IRA's
Deductible IRA
Roth IRA
Nondeductible IRA
Spousal IRA
Education IRAs (now referred to as Coverdell Education Savings Accounts)
Strategies for Investing in IRAs
Section 529 plans-Qualified Tuition Programs
A Bird's Eye View of Sophisticated Estate Planning
Tax Accounting
In General
Transactional Problems
Annual Accounting: Sanford & Brooks
Claim of Right: North American Oil; Lewis
The Tax Benefit Rule
In General: Alice Phelan Sullivan Corp.
Equitable Applications: Hillsboro
Accounting Methods
Overview
The Cash Method
In General
Constructive Receipt
Accounts Receivable
Application: Executive Compensation Arrangements
Prepaid Expenses
The Accrual Method
In General
Income
Deductions: General Dynamics
Current Law: Economic Performance
Prepaid Income: American Automobile Association; Schlude
Credits
In General
Child etc. Care Credit: Smith
Other Credits
Speculations on an Investment Tax Credit
Earned Income Credit ("EIC")
Child Tax Credit
Hope Scholarship Credit and Lifetime Learning Credit: Recap of Tax Assistance to Education
Deduction for Qualified Tuition
Deduction of Interest on Educational Loans
The HOPE Scholarship Credit and the Lifetime Learning Credit
Ethics
General Comments
Standards for Advising Taxpayers on Return Positions
ABA Formal Opinion 85-352
IRS Circular 230-Best Practices and Other Standards
Section 6694
Tax Shelter Rules
ABA Opinion 346
Circular 230-Tax Shelter Opinions
I.R.C. [section] 6700-Abusive Tax Shelters
Conclusion
Appendix: The Miraculous Effects of the Time Value of Money
Capital Gains Rules
Table of Cases
Table of Internal Revenue Code Sections
Table of Treasury Regulations
Table of Revenue Ruling
Index
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