This Article focuses on the decisions of the Tax Court and the UnitedStates Court of Appeals for the Sixth Circuit in Whirlpool Financial Corp. v.Commissioner, that address the scope of subpart F for…
Taxpayers who take advantage of the Code’s exclusions, deductions, andpreferential rates implicitly “vote” on the shape of American society. Pre-TCJA, the Code enfranchised “aspirational” taxpayers w…
One of the foundations of administrative law is that federal agencies andtheir employees are experts in their respective fields. In addition, the manyjudgments and decisions made by these experts are…
Sen. Wyden has proposed dramatic changes to Subchapter K. Probablyno change is further reaching than that made to section 752, which providesthe rules for allocating partnership debt to partners.
Section 1202 provides a significant incentive for investors in smallbusiness stock by allowing them to exclude from their income largeamounts of gain on the sale of this stock.