- Special Note
- Highlights
- Chapter
- History, Policy and Structure
Sec. - 1.01 A Brief History of Income Taxation
- 1.02 Theoretical Aspects of Income Taxation
- 1.03 Structure of the Internal Revenue Code
- Income in General; Compensation for Services
- 2.01 What Constitutes Income in General: Cesarini, Old Colony Trust, Glenshaw Glass and Drescher
- 2.02 Fringe Benefits
- 2.03 Bargain Purchases of Stock or Other Property and Stock Options
- 2.04 Other Items of Compensation Income
- Other Items of Income and Exclusions From Income
- 3.01 Interest
- 3.02 Original Issue Discount
- 3.03 Dividends and Other Distributions to Stockholders
- 3.04 Rents
- 3.05 Royalties
- 3.06 Proceeds From Life Insurance
- 3.07 Annuities
- 3.08 Gifts and Inheritances
- 3.09 Prizes, Scholarships and Fellowship Grants
- 3.10 Discharge of Indebtedness
- 3.11 Recovery of Damages to the Person or Business
- 3.12 Alimony and Similar Payments
- 3.13 Miscellaneous Items of Income and Exclusions From Income
- Income From Dispositions of Property
- 4.01 Overview
- 4.02 The Requirement of a Realization
- 4.03 Computation of Gain or Loss Realized
- 4.04 Disallowance of Some Losses and Exclusion of Some Gains
- 4.05 Recognition of Gain or Loss
- 4.06 Character of Gain or Loss: Capital Gains
- Assignment of Income: Who Is Taxed and the Nature of the Tax
- 5.01 Background
- 5.02 Gratuitous Assignments of Income: Birth of a Metaphor
- 5.03 Assignments of Income for Consideration
- 5.04 Application of Assignment of Income Doctrine
- 5.05 Assignment of Income Without Tears
- Business Deductions
- 6.01 Structural Issues in General
- 6.02 Deductions Arising Out of Business and Profit Seeking Activity
- 6.03 Limitations on Deductions
- Itemized Deductions and Personal Exemptions
- 7.01 Itemized Deductions
- 7.02 Floor on Miscellaneous Itemized Deductions
- 7.03 The Standard Deduction
- 7.04 Personal and Dependency Exemptions
- 7.05 Alternative Minimum Tax
- Tax Planning
- 8.01 Introduction
- 8.02 Tax Shelters
- 8.03 Deferred Payment Sales: Logan
- 8.04 Deferred Compensation: A Survey
- 8.05 A Bird’s Eye View of Sophisticated Estate Planning
- Tax Accounting
- 9.01 In General
- 9.02 Transactional Problems
- 9.03 Accounting Methods
- Credits
- 10.01 In General
- 10.02 Child etc. Care Credit: Smith
- 10.03 Other Credits
- 10.04 Speculations on an Investment Tax Credit
- 10.05 Earned Income Credit (‘‘EIC’’)
- 10.06 Child Tax Credit
- 10.07 Hope Scholarship Credit and Lifetime Learning Credit: Recap of Tax Assistance to Education
- Ethics
- 11.01 General Comments
- 11.02 Standards for Advising Taxpayers on Return Positions
- 11.03 Tax Shelter Rules
- 11.04 Possible Changes in the Future
- 11.05 Conclusion
- Appendix: The Miraculous Effects of the Time Value of Money
- Appendix: Tax Rates After the Jobs and Growth Tax Relief Reconciliation Act of 2003
- Table of Cases
- Table of Internal Revenue Code Sections
- Table of Treasury Regulations
- Table of Revenue Rulings
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