Taxation in Six Concepts: A Student's Guide (2019)

Author(s): Anne L. Alstott

Published: Oct 12, 2018
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ISBN: 9780808050919
Product Number: 10038478-0002
Volumes: 1
Update Frequency: Bi-yearly
200 Pages

Tax doctrines rest on a handful of concepts -- just six, in fact. Armed with six concepts, you can decipher the law. In the United States, more so than in any other developed country, the tax law hosts many of the government's most important social and economic policies. Health care, housing, financial markets, education,and poverty, for example, involve tax. In short, tax turns out to host many interesting and pressing public policy problems.

Taxation in Six Concepts: A Student's Guide (2019) introduces the six concepts and uses them to unpack leading cases and real-world transactions. The six are valuation, net income, realization, tax deferral, substance over form and income-shifting. The cases discussed involve one (or two) of the six concepts discussed. This book also looks beyond the classroom. At every step, real-world transactions are included to show how tax planning harks back to the six concepts.

Of course, tax law, like all law, is full of ambiguity and contradiction. Sometimes there is no single right answer. Courts reach conflicting decisions and use inconsistent reasoning. But the six concepts explain the conflicts within the law that give rise to ambiguity and uncertainty.

The six concepts go a long way in understanding common tax-planning techniques, and the book explains common financial and real estate transactions. It includes a glossary of tax and business jargon, so you have a quick reference when a judicial opinion (or a client) invokes "accelerated depreciation" or "nonrecourse debt."

In fact, the six concepts bring something to the table for the tax specialist too. The best tax lawyers can explain issues in conceptual terms to other lawyers and to clients. No business client appreciates a string of jargon punctuated by section numbers. But clients understand -- and appreciate -- an explanation couched in concepts. Try it. Would you rather hear that "section 265(a)(2) prohibits tax arbitrage subject to the 163 regulations and Rev. Proc. 72-18" -- or that "the tax law gives no relief for your costs when you borrow to buy tax-favored assets"?

Taxation in Six Concepts: A Student's Guide (2019) is now available in an eBook format which you can download to your computer instantly.

  • Table of Contents
  • Taxation in Six Concepts: A Student's Guide (2019)

    Topics and Content

     

    • Introduction
    • How to Use This Book
    • Dedication
    • About the Author

     

    • Chapter 1: The Six Concepts: An Overview
      • ¶100 Introduction
      • ¶101 Valuation
      • ¶102 Net Income
      • ¶103 Realization
      • ¶104 Tax Deferral
      • ¶105 Substance Over Form
      • ¶106 Income Shifting
    • Chapter 2: Salary and Fringe Benefits
      • ¶200 Introduction
      • ¶201 Valuation and the Problem of Measuring Income
      • ¶202 Real-World Transactions: Company Stock and Stock Options ¶203 Fringe Benefits
      • ¶204 Real-World Transactions: Employer-Provided Health Insurance ¶205 Code Section 132
      • Appendix 2-1 Valuation and Fringe Benefits
    • Chapter 3: Gifts and Bequests
      • ¶300 Introduction
      • ¶301 Income Shifting and Code Section 102
      • ¶302 Duberstein
      • ¶303 Real-World Transactions: Bonuses, Tips, and Business Gifts
    • Chapter 4: Marginal and Average Tax Rates
      • ¶400 Introduction
      • ¶401 Two Tax Rates
      • ¶402 Real-World Transactions: The Value of Tax Breaks for Real Estate and Education
      • ¶403 Distribution and the Average Tax Rate
      • ¶404 Old Colony and Substance Over Form
      • ¶405 Real-World Transactions: Signing Bonuses and the Gross Up for Taxes
    • Chapter 5: Gains and Losses
      • ¶500 Introduction
      • ¶501 The Concept of Basis
      • ¶502 Real-World Transactions: Corporate Acquisitions
      • ¶503 When is Basis Recovered? Hort v. Commissioner
      • ¶504 Allocating Basis and Inaja Land Co. v. Commissioner
      • ¶505 Basis Rules for Gifts and Bequests
      • ¶506 Real-World Transactions: Estate Planning and the Income Tax
      • ¶507 Basis and Pre-Nuptial Agreements: Farid-Es-Sultaneh v. Commissioner
    • Chapter 6: The Realization Requirement
      • ¶600 Introduction
      • ¶601 Valuation, Realization and Tax Deferral
      • ¶602 Realization and Windfalls
      • ¶603 Defining Realization: Eisner v. Macomber
      • ¶604 What is a “Sale or Other Disposition”? Cottage Savings Associations v. Commissioner
      • ¶605 Real-World Transactions: Year-End Stock Trading
      • ¶606 Real-World Transactions: Real Estate Swaps
    • Chapter 7: Borrowed Funds
      • ¶700 Introduction
      • ¶701 Valuation and the Exclusion of Borrowed Funds
      • ¶702 Cancellation of Indebtedness: U.S. v. Kirby Lumber Co.
      • ¶703 Zarin v. Commissioner and Code Section 108(e)(5)
      • ¶704 Commissioner v. Tufts and Nonrecourse Debt
      • ¶705 Real-World Transactions: Tax Planning for Bankruptcy and Insolvency
      • ¶706 Borrowing and the Time Value of Money
    • Chapter 8: Business Deductions in General
      • ¶800 Introduction
      • ¶801 Net Income, Deductions, and Exclusions
      • ¶802 Welch v. Helvering
      • ¶803 Exacto Spring Corporation v. Commissioner
      • ¶804 Real-World Transactions: Disguised Dividends and Disguised Gifts
    • Chapter 9: Deductions for Business Meals, Commuting, Clothing, and Child Care
      • ¶900 Introduction
      • ¶901 Business Meals and Moss v. Commissioner
      • ¶902 Commissioner v. Flowers and the Problem of Commuting
      • ¶903 Real-World Transactions: Tax Lobbying and the Restaurant Industry
      • ¶904 Work Clothing and Pevsner v. Commissioner
      • ¶905 Child Care and Smith v. Commissioner
    • Chapter 10: Capitalization and Depreciation
      • ¶1000 Introduction
      • ¶1001 The Value of Tax Deferral
      • ¶1002 Capital Expenditures and Indopco, Inc. v. Commissioner
      • ¶1003 Depreciation and Simon v. Commissioner
      • ¶1004 Real World Transactions: Bonus Depreciation and the Great Recession
    • Chapter 11: Losses and the Interest Deduction
      • ¶1100 Introduction
      • ¶1101 The Interest Deduction
      • ¶1102 Tax Arbitrage and Knetsch v. U.S.
      • ¶1103 Hobby Losses, Storey v. Commissioner, and Nickerson v. Commissioner
      • ¶1104 Real-World Transactions: Wash Sales and Repos
      • ¶1105 Selective Loss Realization and Fender v. United States
    • Chapter 12: Whose Income Is It?
      • ¶1200 Introduction
      • ¶1201 Marriage and Druker v. Commissioner
      • ¶1202 Real-World Transactions: Dividing Property and Income at Divorce
      • ¶1203 Assignments of Earned Income: Lucas v. Earl
      • ¶1204 Assignments of Income Using Entities
      • ¶1205 Assignments of Income from Property: Blair v. Commissioner and Helvering v. Horst
    • Chapter 13: Capital Gains
      • ¶1300 Introduction
      • ¶1301 The Preferential Rate
      • ¶1302 The Capital Loss Limitation
      • ¶1303 Real-World Transactions: Sale of a Closely-Held Business
      • ¶1304 What is a Capital Asset?
      • ¶1305 Real-World Transactions: Stocks and Bonds
      • ¶1306 Conversion and Bramblett v. Commissioner
    • Chapter 14: Putting it All Together -- Tax Shelters
      • ¶1400 Introduction
      • ¶1401 Estate of Franklin
      • ¶1402 Frank Lyon Co. v. U.S.
      • ¶1403 ACM Partnership v. Commissioner
    • Appendix A: A Glossary of Tax and Business Jargon
    • Appendix B: How to Answer an Issue-Spotter Exam Question
    • Appendix C: Roadmaps to Major Casebooks
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