JATA - Fall 1983

Volume 5, No. 1

Tax Court Classification of Activities Not Engaged in for Profit: Some Empirical Evidence

Jack Robison

Abstract

The results of this study are based on the analysis of 219 post-1954 Tax Court cases involving determination of whether activities are or are not engaged in for profit. Profit analysis was used to identify and estimate the relative importance of factors used by the Tax Court in deciding this issue. Five factors were found to be significant predictors: manner of operation, level of expertise, time expended, history of income and loss, and the presence of elements of personal pleasure. Log-likelihood techniques were used to determine that the factors used by the Tax Court were not significantly altered by the passage of Section 183 and were stable across lines of "business."


The Analysis of Tax Court Decisions That Assess the Profit Motive of Farming-Oriented Operations

Jane O. Burns and S. Michael Groomer

Abstract

This study employs multiple discriminant analysis to investigate Tax Court decisions that examine whether farming activities are pursued with an intent to make a profit. The population of 151 cases heard in the Tax Court through 1980 was used to develop linear discriminant models for three separate time periods. A number of techniques not previously used in studies of this nature were employed to comprehend more fully the nature of judicial decision-making in this area. The results indicate that some shift in the variables considered important by the judiciary took place over time. In recent years, the Tax Court has begun emphasizing a number of variables specified within the regulations.


The Certification of Tax Specialists: Some Empirical Results

C. Douglass Izard and John D. McKinney

Abstract

The certification of specialists in accounting has developed into a controversial topic. This study was based on a questionnaire survey of 274 southeastern accountants and their perceptions and attitudes about the certification of tax specialists. The analysis considered a comparison among the three groups sampled and the aggregate sample through the use of chi-square analyses. The results indicate possible support for a special certification of tax specialists as well as indications of certification requirements and post-certification requirements. The over-all results have important implications for the development of an acceptable tax specialists' certification program.


Doctoral Program with a Concentration in Taxation: An Examination of Recent Trends

Richard Boley and Edmund Outslay

Abstract

There has been a considerable increase in the number of persons enrolled in and graduating from doctoral programs with a concentration in taxation. This article analyzes that growth and provides a profile of the doctoral programs of twenty-seven schools that identified themselves as offering such a program. The information and related observations provided in this article are intended to aid prospective doctoral students in identifying potential schools for their studies and to aid tax educators in recommending (or designing) doctoral programs in taxation.

Letter from the President

To ATA Members and Visitors,

The American Taxation Association (ATA) is home to a broad group of members with interests in tax research, policy, practice, and education. We are in a time of transition that includes the ongoing pandemic; both AAA’s and ATA’s Diversity, Equity, and Inclusion initiatives; and the CPA Evolution. I thank our members Kirsten Cook, Diana Falsetta, and Annette Nellen for their service in these endeavors. I also thank Tim Rupert for his service as AAA Director focusing on Segments.

Our last mid-year meeting was virtual and could not have happened without our excellent ATA leadership. Thank you to Jeri Seidman, Mollie Adams, Bridget Stromberg, and their respective committees for their flexibility and tenacity in organizing their portions of the conference...

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Anna Catherine Fowler

In Memoriam,
Anna Catherine Fowler received her BS in accounting from the University of Alabama, after which she practiced for several years as a CPA. After moving to Texas with her husband Jim, she earned her MBA and PhD from the University of Texas at Austin.

She joined the faculty of the business school of the University of Texas in 1977 as the first female tenure track professor hired by the accounting department. She remained at UT until she retired in 2004 as the John Arch White Emeritus Professor in Business.

During Anna’s distinguished academic career, her research and teaching interests focused on estate and gift taxation. She was an active member of the AICPA’s Tax Division and the American Taxation Association, for which she served as 1993-94 president.

In 2002, Anna received the American Taxation Association’s highest honor, the Ray M. Sommerfeld Outstanding Tax Educator Award. She also received the Texas Society of CPA’s Outstanding Educator Award.

Anna and Jim made the most of their retirement years, delighting in travel all over the world. They finally settled in a retirement community in Chapel Hill, North Carolina. Even after Jim’s death in 2019, Anna continued to travel with friends, root for her beloved Alabama football team, and live her life to the fullest. She passed away peacefully on October 19, 2021.

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