This paper examines the tax code provisions that encourage home ownership, including a discussion of some new legislation that also falls within the current administration's economic stimulus package. It reviews tax provisions dealing with buying a home, owning a home, and selling a home, as...

One of the most notable examples of U.S. tax exceptionalism is the taxation of U.S. citizens and legal permanent residents (LPRs) on their worldwide income, regardless of residence. The United States also imposes broad and increasingly onerous tax and financial reporting obligations on its...

El ICIO es un impuesto muy controvertido por diversos motivos que van desde cuál sea su verdadera naturaleza, pasando por su «descendencia» de la tasa por licencia de obras y por atentar contra el principio de igualdad, hasta la concurrencia del mismo con varios tributos. Se han escrito ríos...

El Impuesto sobre Bienes Inmuebles (IBI) es un tributo muy controvertido por dos razones: la primera por el sistema de determinación del valor catastral, y la segunda por concurrir con múltiples figuras tributarias. En cuanto a la primera, la determinación de dicho valor aleja al IBI del...

It is difficult to value fractional interests in art because there is virtually no market in those interests. Nevertheless, the Tax Court in Estate of Elkins valued the decedent's fractional interests in multiple artworks, which the decedent and his children highly cherished. First, the court...

There are two principal rationales for the charitable deduction. Depending upon choice of rationale, some tax reform changes are suggested and others are not. A base measurement rationale suggests eliminating the deduction for unrealized appreciation, keeping the benefit as a deduction and not a...

In Sommers, ruling on both parties' motions for partial summary judgment, the Tax Court dealt with claims of issue preclusion and collateral estoppel, equitable apportionment, the completion of gifts of limited liability company interests, and retained powers that would cause estate tax...

In Wimmer, the Tax Court held that the income stream from a taxpayer's gifts of family limited partnership interests was eligible for the annual exclusion. By comparing the income interest in the partnership's dividend paying marketable securities to the income interest in a trust, the court...

The thesis of this article is that the tax expenditure concept is grounded on an erroneous vision of the structure of an income tax system. The tax expenditure concept adopts a binary view of income taxation. It posits that there is an ideal or pure income tax system whose provisions are...

The U.S. stands on the precipice of a financial disaster, and Congress has done nothing but bicker. Of course, I refer to the coming day when the undead walk the earth, feasting on the living. A zombie apocalypse will create an urgent need for significant government revenues to protect the...