JATA - Summer 1981

Volume 3, No. 1

The Proper Charge to Capital:  Jarvis and its Implications

Allen Ford & John Robinson

ATA Summary

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

ATA Summary

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

ATA Summary

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

ATA Summary

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.

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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