Articles Tagged “IRS”
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 the case. [The court’s] inquiry must cease if the statutory language is unambiguous and the […]
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].” In response, a Patent Office spokesperson said, “The [Patent Office] has a long tradition of […]
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 watched the television show Melrose Place. Deeply concerned about his pending polygraph examination, he turned […]
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 the statutory pieces together to form a sensible picture. The procedural pieces of the puzzle, […]