IRS

Like fences, the statutes in subtitle F of the code define the operational area in which the IRS administers the tax laws. Statutory words — like pickets — place important boundaries on IRS action. Statutory silence — the spaces surrounding the words — can be just as important in understanding the boundaries. As with any other aspect of language, meaning comes from both what is said and what is not said. This...

Written by: Steven A. Dean and Lawrence M. Solan I. INTRODUCTION Tax shelters raise difficult problems of statutory interpretation. In her interesting article, Of Lenity, Chevron, and KPMG,[1] Kristin Hickman explores one of them: the recent tendency of courts to apply the rule of lenity in civil cases, potentially leading to a narrow interpretation of the Internal Revenue Code (Code) that would undermine efforts...

In every era and area of law you find a never-ending battle between two groups of legal thinkers: formalists and functionalists. Each is connected to long-standing and honorable traditions in Anglo-American jurisprudence. The formalists tend toward the law side of those traditions the search for order and certainty and the functionalists tend toward the equity side the search for justice and meaning. All can agree that...

The partnership tax provisions – Subchapter K of the Internal Revenue Code – work pretty well. And they have a difficult job to do because they must provide a reasonable mechanism for taxing arrangements between parties that can be far from off-the-rack. It should not be difficult to figure out how to tax two individuals who contribute equal amounts of cash to start a joint business in which each will own a one-half...

I. INTRODUCTION In the wake of the events surrounding President Bush's endorsement of a constitutional ban on same-sex marriage,[2] a conservative, “pro-family“ organization[3] wrote the Commissioner of the Internal Revenue Service (IRS) earlier this year to alert him about “a potential fraudulent tax scheme.“[4] The organization was alarmed by “rebellious state and local officials reportedly permitting...

I love my yearly tax refund. I know I'm not supposed to, but I do. Theorists argue that my refund represents an interest-free loan to the government and I am supposed to resent that for reasons grounded in the obsessive individualism of our culture. But even accepting the argument's premise, the value to me of that yearly manifestation of my forced savings outweighs the value of the interest I would theoretically earn...

The Tax Lawyer—Robert Wood "IRS Bill Dispute" law,lawyer,IRS,Billnews,lbnfinances,rob,wood,financial Author: LBNstudio

Taxnami 2011 - , Credits and Funding of the Healthcare Legislation IRS,2010,2011,2012,2013,2014,healthcare,legislation Author: Berrylawoffices

Things are getting ever more uncomfortable for U.S. taxpayers holding undisclosed offshore bank and investment accounts. And in the wake of the very public fight between the Internal Revenue Service and Union Bank of Switzerland (UBS), it is quite possible that one of your clients will reveal to you that he has an offshore account he "forgot" to mention. Your advice to such a client will need to be informed by an...

Taxnami 2011 - How much is grandma going to be taxed? ,estate ,2011,2010,2012,IRS,estate planning Author: Berrylawoffices

Sheldon Hosts Information Session for Small Businesses on New Tax Credits Sheldon Whitehouse,Senator Whitehouse,small business,SBA,health care reform,Small Business Jobs Act,Rhode Island,IRS,tax breaks Author: SenatorWhitehouse

After the Bankruptcy Abuse Prevention and Consumer Protection Act you thought it couldn't get any worse for your tax delinquent clients? Wrong again. The latest Congressional gift to the IRS Collection Division is Section 509 of the Tax Increase Prevention and Reconciliation Act of 2005 (TIPRA). One must at least give grudging credit to the Congress for creative captioning, even though the substance of the law has little...