Jeffrey L. KwallSocial ence Electronic Publishing
Internal Revenue Code of 1986 SUBTITLE F -- PROCEDURE AND ADMINISTRATION Chapter 66 -- Limitations Subchapter B -- Limitations on Credit and Refund (a)Period of limitation on filing claim. Claim for credit or refund of an overpayment of any tax imposed by this title in respect of which tax...
(3)subparagraph (B) of section 1030(a)(2) of title 18, United States Code, the Secretary shall notify such taxpayer as soon as practicable of such inspection or disclosure. The Secretary shall also notify such taxpayer if the Internal Revenue Service or a Federal or State agency (upon not...
Anachronisms in Subchapter K of the Internal Revenue Code: Is It Time to Part with Section 736?Brutus: Peace! Count the clock. Cassius: The clock hath stricken three. Trebonius: 'Tis time to...Postlewaite, Philip F.Rosenzweig, Adam H....
Examines the anachronisms in Subchapter K provision of the Internal Revenue Code section 736 in the U.S. enacted to settle tax treatment of payments by a partnership to a retiring partner or to a successor. Information on the structure and operation of the Subchapter K provision; Influence of...
was quickly repudiated by the Revenue Act of 1924,' but in 19348 the still more drastic technique of treating all liquidating gains as short-term capital gains was adopted. In the field of complete liquidations this lasted only until the Revenue Act of 1936;' but, because of the supposed ...
The brand new world of S corporation reorganizations. (Internal Revenue Code Subchapter S)Karlinsky, Stewart S
ESOPs and S corporations. (employee stock ownership plans, Internal Revenue Code Subchapter S)Smith, Greg W
(2008), `Fifteen and Thirty Five-Class Warfare in Subchapter K of the Internal Revenue Code: The Taxation of Human Capital Upon the Receipt of a Proprietary Interest in a Business Enterprise', Northwestern University School of Law, Faculty Working Paper 170, 28, at pages 1-68....
Planning for a QSSS. (qualified Internal Revenue Code Subchapter S subsidiaries)Huizenga, David L