Abusive Tax Shelters: Hearing Before the Subcommittee on Oversight of the Internal Revenue Service of the Committee on Finance, United States Senate, Ninety-eighth Congress, First Session, June 24, 1983
United States. Congress. Senate. Committee on Finance. Subcommittee on Oversight of the Internal Revenue Service
U.S. Government Printing Office, 1983 - Electronic books - 168 pages
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abusive tax shelters additional allocation allowed amount apply audit avoid basis believe benefits bond borrowed capital capital gain cash Chairman charitable claim close Code collections Commissioner committee Congress continue contribution corporation cost Court deal deductions deferred Department determined discount earnings economic effect enacted examination example exchange expenses foreign funds future gain going held holding income increased individual interest Internal Revenue Code Internal Revenue Service investment investors involved issue Judge legislation liability limited loan loss method months obligation obtain ordinary income paid partnership payments penalty percent period position present problem promoters proposed provisions purchase questions received recently reduce regulations result returns rules schemes Senator Grassley shares statement straddle Subcommittee substantial Tax Court taxable taxpayer TEFRA term tion trade transactions Treasury treated types
Page 115 - was ever intended to apply to exchanges of partnership interests. Section 1031 does not apply to exchanges of stock, certificates of trust or beneficial interest, or "other securities or evidences of . . . interest." Partnership interests can be viewed as investment interests
Page 31 - For contributions of inventory-type property, fair market value is the price which the taxpayer would have received if he had sold the property in the ordinary course of business. Treas. Reg- sec. 1.170Al(cX2). *• Sec. 170(eXlXA).
Page 8 - percent in value of its outstanding stock is owned (directly or indirectly) by 5 or fewer individuals.
Page 109 - any partner with a deficit balance in his capital account following the distribution of liquidation proceeds is required to restore the amount of such deficit to the partnership.
Page 27 - who acquires his interest late in the taxable year from deducting partnership expenses incurred prior to his entry into the partnership, so-called "retroactive allocations" of partnership losses. Some taxpayers take the position that, in applying this restriction, partnership income and losses are considered to pass through to
Page 40 - THE INTERNAL REVENUE MANUAL CONTAINS WHAT WE HAVE FOUND TO BE USEFUL WORKING DEFINITIONS OF ABUSIVE AND NON-ABUSIVE TAX SHELTERS. THOSE DEFINITIONS MAKE THE FOLLOWING DISTINCTIONS: NON-ABUSIVE TAX SHELTERS - INVOLVE TRANSACTIONS WITH LEGITIMATE ECONOMIC REALITY. WHERE THE ECONOMIC BENEFITS OUTWEIGH THE TAX BENEFITS. SUCH SHELTERS SEEK TO DEFER OR MINIMIZE TAXES.
Page 1 - met, pursuant to notice, at 9:38 am in room SD215, Dirksen Senate Office Building, Hon. Charles E. Grassley (chairman) presiding. Present: Senators
Page 155 - revisions to the Treasury Department's Circular 230 incorporate much of Opinion 346 of the Standing Committee on Ethics and Professional Responsibility of the American Bar Association, which sets forth the standards and ethical considerations which should be applicable to opinions by lawyers analyzing the tax effects of an investment in a tax shelter offering. Responsible members of the tax bar have the same interest as