Volume 55, No. 4 - Summer 2002

Articles

Choice of Entity for a Venture Capital Start-up: The Myth of Incorporation

Daniel S. Goldberg

Most tax professionals would advise entrepreneurs to commence their start-up business as a limited liability company, which, absent an election, is treated as a partnership for federal tax purposes. ...

How the Board of Tax Appeals Changed Hollywood History

Allen Rostron

Everyone remembers when Charlton Heston, as Moses, held his staff toward the heavens and the Red Sea parted in Cecil B. deMille's epic motion picture The Ten Commandments. Few know the curious tale of tax law that lies behind it. ...

Notes

The Real Estate Exception to the Passive Activity Rules in Mowafi v. Commissioner and the New Burden Shifting Statute

Pedram Ben-Cohen

In Mowafi v. Commissioner, the Tax Court held that the taxpayer did not meet the burden of proof required for the real estate professional exception to the passive activity rules. The court found that the taxpayer's inconsistent testimony combined with...

Supreme Court Tips the Balance in Favor of the Service by Authorizing Aggregate Assessment of Unreported Employee Tips: United States v. Fior d'Italia, Inc.

Stephen P. Goldberg

In United States v. Fior d'ltalia, the Supreme Court held that the Service is authorized to impose a Federal Insurance Contributions Act (FICA) tax on a restaurant based on an aggregate estimate of the unreported tips of the restaurant's tipped employees. ...

(It's All in a Parenthetical) An Analysis of the FSC Provisions as Applied in Microsoft v. Commissioner

Eric D. Hayes

In Microsoft v. Commissioner, the Tax Court held that domestically-produced copyrighted computer software transferred abroad on a master, then reproduced and sold, does not constitute export property. Therefore, the profits generated from its sale do not receive...

"No, You Still Can't Deduct that Payment to Your Child's Private Religious School:" An Analysis of the Ninth Circuit Decision in Sklar v. Commissioner

Eric Hildenbrand

In Sklar v. Commissioner, the Ninth Circuit held that, under section 170 of the Code, taxpayers may not deduct the portion of tuition payments made to private schools that represent the portion of the school day spent on religious study. ...

Important Developments During the Year

ABA Section of Taxation

Tax Section Committee Important Developments Reports.

Index

Index to Volume 55

ABA Section of Taxation

This index includes articles, committee reports, and student notes that appear in volume 55 of The Tax Lawyer.

The Tax Lawyer

The Tax Lawyer, the nation’s premier, peer-reviewed tax law journal, is published quarterly as a service to its members by the American Bar Association Section of Taxation. Abstracts can be viewed by anyone, but full text pdfs are accessible only to members of the Section. Section members may also view the Spring 2018 issue of The Tax Lawyer in its entirety.

Subscribing

If you are an ABA member, you can receive The Tax Lawyer when you join the Section of Taxation. Anyone can subscribe to The Tax Lawyer by contacting the ABA Service Center at service@americanbar.org.

Vol. 55, No. 4 - Summer 2002

The Tax Lawyer, Summer 2002

Articles

Choice of Entity for a Venture Capital Start-up: The Myth of Incorporation

How the Board of Tax Appeals Changed Hollywood History

Notes

The Real Estate Exception to the Passive Activity Rules in Mowafi v. Commissioner and the New Burden Shifting Statute

Supreme Court Tips the Balance in Favor of the Service by Authorizing Aggregate Assessment of Unreported Employee Tips: United States v. Fior d'Italia, Inc.

(It's All in a Parenthetical) An Analysis of the FSC Provisions as Applied in Microsoft v. Commissioner

"No, You Still Can't Deduct that Payment to Your Child's Private Religious School:" An Analysis of the Ninth Circuit Decision in Sklar v. Commissioner

Important Developments During the Year

Important Developments During the Year

Index

Index to Volume 55

The Tax Lawyer

Subscribing

American Bar Association TM American Bar Association

Vol. 55, No. 4 - Summer 2002

The Tax Lawyer, Summer 2002

Articles

Choice of Entity for a Venture Capital Start-up: The Myth of Incorporation

How the Board of Tax Appeals Changed Hollywood History

Notes

The Real Estate Exception to the Passive Activity Rules in Mowafi v. Commissioner and the New Burden Shifting Statute

Supreme Court Tips the Balance in Favor of the Service by Authorizing Aggregate Assessment of Unreported Employee Tips: United States v. Fior d'Italia, Inc.

(It's All in a Parenthetical) An Analysis of the FSC Provisions as Applied in Microsoft v. Commissioner

"No, You Still Can't Deduct that Payment to Your Child's Private Religious School:" An Analysis of the Ninth Circuit Decision in Sklar v. Commissioner

Important Developments During the Year

Important Developments During the Year

Index

Index to Volume 55

The Tax Lawyer

Subscribing