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Part Two by Joel Rabinovitz
Background and Purpose of the New Provisions
Part Three by Charles Davenport
Act law Act of l969 adjusted gross income alternative tax amount realized applicable percentage appreciated property basis bonds capital loss carry investment carrybacks carryover Charles Davenport computed controlled group Davenport University debt debt-equity deduction deferred compensation disposition distribution earned income earned taxable income earnings and profits election exceeds fair market value franchise franchisor hobby losses holding period income averaging income tax investment income investment interest joint return July 24 l969 additional depreciation limited long-term capital gain long-term loss minimum tax October 9 option ordinary income paid payments post l969 additional private foundation provisions real estate redemption reduced residential rental property restricted stock restrictions risk of forfeiture School of Law section l250 property shareholders shares small businesses stock dividend Subchapter S corporations substantial risk tax preference item Tax Reform Act term capital gain tion transactions in securities transfer treated trust University of California