Deducting interest on federal income tax underpayments: a roadmap through a 50-year quagmire
Article Abstract:
The IRS stance that interest on business-related tax liabilities and penalties is not deductible by individuals is supported by legislative actions, but allowing such deductions would be better tax policy. Congress curtailed individual interest deductions in 1986, and legislative histories suggest that it intended to make interest deductions unavailable for personal tax liabilities incurred in a trade or business. From a policy perspective, however, there is no reason why tax-related business expenses should be non-deductible when comparable non-tax expenses are deductible.
Publication Name: Virginia Tax Review
Subject: Law
ISSN: 0735-9004
Year: 1996
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Losing face but gaining power: state taxation of interstate commerce
Article Abstract:
The courts should replace traditional dormant Commerce Clause analysis employed when state taxation affects interstate commerce with an approach that acknowledges the division of power between the federal and state governments at issue. The traditional analysis has focused on whether the tax measure discriminates on its face against out-of-state taxpayers. The alternative test employed has been an open-ended balancing test. Separation of power analysis should be paired with cost-benefit analysis to adequately consider all the state and federal interests implicated.
Publication Name: Virginia Tax Review
Subject: Law
ISSN: 0735-9004
Year: 1997
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Borrowing, return of capital conventions, and the structure of the income tax: an essay in statutory interpretation
Article Abstract:
Interpretation of income tax provisions of the Internal Revenue Code requires the understanding that no single principle underlies the provisions. The transaction-based provisions are the result of ad hoc balances between accrual and consumption-based taxation. An analysis of purported principles underlying the nontaxability of debt incurrance illustrates, using ad hoc return of capital provisions, the lack of principled underpinnings of income tax provisions.
Publication Name: Virginia Tax Review
Subject: Law
ISSN: 0735-9004
Year: 1998
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