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Under the U.S. Constitution as amended by the Sixteenth Amendment, any federal tax that is a quot;direct taxquot; (which is not an quot;income taxquot;) must be apportioned among the states in accordance with the respective populations of the various states. The purpose of this Article to solve...
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In this article, Dodge examines the tax treatment of borrowing under the income tax. The current income tax treatment is contrasted with a cash-method treatment, which is inclusion of borrowed funds coupled with the deduction of the principal and (where appropriate) the interest. (An alternative...
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This short review essay evaluates the Practicing Law Institute's Circular 230 Deskbook by Jonathan G. Blattmachr, Mitchell M. Gans and Damien Rios. For attorneys, accountants and others who practice before the IRS, the Circular 230 Deskbook is a masterful analysis and an important guide to the...
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Janet Halley proves that third-wave feminism is wrong - wrongly described, that is. Young feminists in the United States tout a quot;third wavequot; of feminism that is hip, ironic and playful - the supposed opposite of the dour and strident quot;second wavequot; of 1970's feminism. Goodbye...
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The marital deduction provisions suggest a unique application of the rule of consistency. The deduction provides only the benefit of deferral and only on the rationale that the actual transfer occurs at the termination of the marital unit, that is, at the surviving spouse's death. The statute of...
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