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 , , , , , , , , , , , , | Comments Off

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 , , , , , , , , , , | Comments Off

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

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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

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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

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