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Don’t Let Capital Accounts Go Negative

Calvin Johnson
The proposal would prevent negative capital accounts as a remedy to prevent tax shelters. It would suspend deductions that would otherwise result in the taxpayer’s adjusted basis being lower than the...
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Tax Fraud Investigations – A Procedural Road Map – Part II

Burton J. Haynes
Joseph M. Jones I. Introduction In the last issue of the Corporate Criminal Liability Reporter, Spring 1988, we described the process involved in IRS criminal investigations -- how they begin, the...
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The Political Economy of Taxation: Positive and Normative Analysis when Collective Choice Matters

Stanley L. Winer* Walter Hettich** Abstract In this paper we review both positive and normative aspects of taxation. We examine how to study why taxes and revenue structures have taken their present...
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Coping through California’s Budget Crises in Light of Proposition 13 and California’s Fiscal Constitution

David Gamage
When Proposition 13 passed in 1978, many commentators predicted disaster for California's state and local finances. Now, 30 years later, California is experiencing severe fiscal instability and a round...
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Omnibus Capitalization Proposals

Calvin Johnson
This shelf project proposal covers several expenditures that are allowed as expenses as soon as they are incurred under current law but should be treated as capital expenditures. Given the treatment of...
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Comments on the OECD Proposal for Secret and Mandatory Arbitration of International Tax Disputes

Michael Mcintyre
The OECD has proposed amendments to its Model Tax Convention and Commentary that would establish a system for the mandatory arbitration of tax disputes between two treaty countries when the tax officials...
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What Good Is The National Taxpayer Advocate?

Bryan T. Camp
Bryan Camp and George H. Mahon Have you read the National Taxpayer Advocate's 2009 Annual Report? You know, the yearly 800-page compendium listing the 20 most serious taxpayer problems, recommending...
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A New Understanding of Tax

Edward Mccaffery
Written by: Edward J. McCaffery I. INTRODUCTION A. Loomings Perhaps we should blame it all on Mill. A great deal and possibly all of the mind-numbing complexity of America’s largest and least...
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The Statute of Limitations on collection

Burton J. Haynes
For those beleaguered souls for whom nothing else works, the only hope of relief from unmanageable federal tax debts may be the statute of limitations on collection. In theory, the IRS has only 10 years...
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Which is Worse,Tax Fluctuations or Spending Fluctuations?

David Gamage
Acknowledgements: Many thanks to Michael Abramowicz, Bruce Ackerman, Anne Alstott, Alan Auerbach, Ian Ayres, Robert Bartlett, Lily Batchelder, Mitch Berman, Neil Buchanan, Terry Chorvat, Mechele Dickerson,...
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