The Proper Charge to Capital: Jarvis and its Implications
Allen Ford & John Robinson
The article describes the evolution of interpretation of Section 312(e). The courts have consistently maintained that when amounts are distributed in partial liquidation or in a redemption to which Section 302(e) or Section 303 applies, The proper charge to capital is a pro rata charge. Since the balance of the distribution may eliminate or reduce E&P by more than a pro rata amount, such distributions may significantly affect future tax planning opportunities. In light of the importance of Jarvis, taxpayers should be even more aware of the tax planning opportunities.
Research Methodology: The research methodology employed in the paper is that of legal research.
Graduate Tax Libraries: A Survey of Their Content and Funding
R. L. Black & A. G. McMahon
A survey of graduate tax directors and tax librarians was undertaken to determine the funding levels and library contents of different types of graduate tax programs. Responses suggested that, at the time of the survey, about $6.000 in annual funding was required to maintain an average graduate tax library. The survey also yielded a list by title of most services, serials, Journals and newsletters maintained at the reporting institutions.
Research Methodology: A survey collected data which was then categorized by the authors on a judgmental basis. In some cases averages were taken. No statistical analysis was performed. Tables of data or summaries of results are presented in the article.
CPA Examination Tax Problems: An In-Depth Analysis
J. M. Weiss & I. Blumenfrucht
The primary areas tested on past CPA examinations are those relating to individual taxpayers, capital assets, and assets used in a trade or business. The specific tax laws and rules within each of these areas that have been tested with the greatest frequency on past CPA examinations are reflected in the CPA Examination Tax Frequency Distribution Tables presented in the article.
Research Methodology: The tables reflect the numer of times various areas of Federal income tax have been tested in the objective, multiple-choice problems presented in CPA examinations given from Nov. 1973 through May 1981. No further analysis is done on the data other than to list the number occurring in each category.
Installment Sales: Temporary Regulations Inconsistent with Judicial Definition of Payment
R. W. Wyndelts & A.C. Fouler
The Installment Sales Revision Act of 1980 contains no language providing that indebtedness secured by cash or certificates of deposit fails within the purview of the term "payment.” The temporary regs. have gone beyond the intent of Congress by expanding the scope of the meaning of payment, as previously interpreted by the judiciary.
Research Methodology: The paper uses legal research methodology. No numerical examples are presented.