Mr. Popeil gets 'reel' about conversions of legal entities: the pocket fisherman flycasts for "form" but snags on "substance." (form and substance characterizations of entity conversions)(50th Annual Federal Tax Conference of the University of Chicago Law School)
Article Abstract:
Conversions of legal entities has increased with the proliferation of new forms of limited liability entities, but the IRS's inconsistent treatment of conversions remains. The IRS has issued contradictory private and public rulings stressing either form or substance analysis in this area where there is much formal regulations, statutory authority, and case law. Taxpayer and IRS administration costs would be lessened and uniformity and predicability increased if form controled in all situations except where substance is mandated by congressional or judicial policy.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1997
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Final regulations on return preparers' penalties: IRS refuses to deal, preparers' fears prove to be real/penalty roulette - roll the wheel/who knows how the courts will feel?
Article Abstract:
Tax advisors and preparers of tax returns may be subject to a penalty under Section 6694 of the Internal Revenue Code if they understate a taxpayer's liability. Regulations under Sections 6662 and 6664 may impose penalties on taxpayers for errors related to the accuracy of tax returns. The Improved Penalty Administration and Compliance Tax Act of 1989 amended the penalties on preparers of returns under Section 6694. Several issues have not been resolved by the final regulations.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1992
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Final regulations on accuracy-related penalties: taxpayers beware, the Feds are out there/there's danger in the air - be aggressive if you dare!
Article Abstract:
The Internal Revenue Service, on Dec 31, 1991, issued final regulations dealing with the penalties related to the accuracy of tax returns. The Improved Penalty Administration and Compliance Tax Act of 1989 incorporated accuracy-related regulations into Section 6662 of the Internal Revenue Code. The final regulations deal with penalties related to the disregard of tax rules, negligence, tax understatements and valuation misstatements.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1992
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- Abstracts: The birth of clinical accounting: a study of the emergence and transformations of discourses on costs and practices of accounting in U.S. hospitals
- Abstracts: IRS valuation methods lag behind business practice. Definitions of personal service corporations vary. Tax procedure considerations in Chapter 11 reorgs
- Abstracts: Borden salts its snacks as profits plunge: The No. 2 player faces a make-or-break year. RJR's wrap attack
- Abstracts: Tax planning for noncorporate bankruptcies. The IRS's whole hospital joint venture ruling: guidance or confusion?