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Current Issue
Jan. 2013, Vol. 65, No. 1
Articles
David Haddock, Tonja Jacobi, & Matthew Sag, League Structure &Stadium Rent Seeking— the Role of Antitrust Revisited
Steven J. Cleveland, Resurrecting Deference to the Securities and Exchange Commission: Mark Cuban Trading on Inside information
Janai S. Nelson, The First Amendment, Equal Protection and Felon Disenfranchisement: A New Viewpoint
Sergio J. Campos, Erie as a Choice of Enforcement Defaults
Hanah Metchis Volokh, Constitutional Authority Statements in Congress
Sapna Kumar, The Accidental Agency?
Christian Turner, State Action Problems
Tag Archives: internal revenue service
Lindsay Roshkind, Interpreting I.R.C. § 67(e): The Supreme Court’s Attempt to Nail Investment Advisory Fees to the “Floor”
60 Fla. L. Rev. 961 (2008) | | | | TEXT :: In the process of statutory interpretation, a court must determine “whether the language at issue has a plain and unambiguous meaning with regard to the particular dispute in … Continue reading
Posted in Estates & Trusts Law, Governments and Legislation, Securities Law, Uncategorized
Tagged 63, 67(e), Advisory Fees, fiduciary duty, I.R.C., institutional investment management, Internal Revenue Code, internal revenue service, IRS, Nail Investment, Roshkind, tax deficiency, trust
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William A. Drennan, The Patented Loophole: How Should Congress Respond to this Judicial Invention?
59 Fla. L. Rev. 229 (2007) | | | | INTRODUCTION :: An IRS spokesperson “questioned whether the [Patent Office] staff has adequate background in tax law . . . to properly rule on those patent applications [for tax strategies].” … Continue reading
Posted in Governments and Legislation, Patent Law, Tax Law, Uncategorized
Tagged CPA, internal revenue service, IRS, license fees, novelty and nonobviousness, Patent Office, tax loopholes, tax planners, tax practicioners, tax strategies, Treasury Department
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Daniel J. Glassman, “It’s Not a Lie if You Believe it”: Tax Shelters and the Economic Substance Doctrine
58 Fla. L. Rev. 665 (2006) | | | | INTRODUCTION :: In an episode of Seinfeld, Jerry was confronted with the requirement of taking a polygraph test after denying, to a woman police-officer whom he was dating, that he … Continue reading
Posted in Tax Law, Uncategorized
Tagged Accounting, Bill Clinton, Business Losses, Economic Substance Doctrine, Glassman, honesty, internal revenue service, IRS, legal accuracy, loopholes, Seinfield, sympathetic judges, tax code, tax loopholes, Tax Shelters, transaction costs
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John D. Colombo, In Search of Private Benefit
58 Fla. L. Rev. 1063 (2006) | | | | INTRODUCTION :: For at least the past two decades, the Internal Revenue Service (IRS) has relied heavily on the private benefit doctrine to police economic transactions between tax- exempt charities … Continue reading
Posted in Business & Corporate Law, Tax Law, Uncategorized
Tagged 501(c)(3), ancillary joint ventures, balancing test, charities, Colombo, exempt charity, exempt educational organization, exempt entities, internal revenue service, IRS General Counsel Memorandum, joint ventures, major political party, Policing tool, Private Benefit, private benefit doctrine, Revenue Ruling 2004-51, secondary private benefit, tax-exempt, Treasury Regulation § 1.501(c)(3)-1(d)(1)(ii)
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Bryan T. Camp, Tax Administration as Inquisitorial Process and the Partial Paradigm Shift in the IRS Restructuring and Reform Act of 1998
56 Fla. L. Rev. 1 (2004) | | | | INTRODUCTION :: The tax code is a puzzle. Whether one views it as an engaging enigma or a ridiculous riddle, the tax code requires careful and considered attention to fit … Continue reading
Posted in Administrative Law, Civil Procedure, Tax Law, Uncategorized
Tagged Camp, Inquisitorial Process, internal revenue service, Internal Revenue Service and Restructure act, IRS, IRS Restructuring and Reform Act, Paradigm Shift, RRA, Senate Finance Committee, tax academics, Tax Administration, tax code, tax compliance, tax procedure, tax writers, taxwriters
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