This paper proposes various moves for simplification of the task of computing the tax base under the individual income tax, with a principal view of making the income tax capable of compliance by “ordinary” individuals without the aid of tax preparation software or outside assistance....

The idea advanced herein, as a thought experiment, is the possibility of expanding (by legislation) – or possibly interpreting (by Treasury regulation) – section 265(a)(1) to disallow deductions deemed to have paid out of tax-exempt (i.e., excluded) income. Although section 265(a)(1) already...

Under the U.S. Constitution as amended by the Sixteenth Amendment, any federal tax that is a quot;direct taxquot; (which is not an quot;income taxquot;) must be apportioned among the states in accordance with the respective populations of the various states. The purpose of this Article to solve...

The principal thesis is that, under the federal income tax, costs of obtaining specific sums of money should be capitalized (as opposed to being treated as expenses), just as costs of obtaining property should be so capitalized. Since this article deals with costs of obtaining or receiving...

In this article, Dodge examines the tax treatment of borrowing under the income tax. The current income tax treatment is contrasted with a cash-method treatment, which is inclusion of borrowed funds coupled with the deduction of the principal and (where appropriate) the interest. (An alternative...

The thesis here is that inconsistent tax accounting rules undermine the individual income tax, and the best available move for improving it — given the unassailability of the realization principle — is to eliminate its accrual (and quasi-accrual) features. Specifically, the agenda is to...

The thesis is that inconsistent tax accounting rules undermine the individual income tax, and the best available move for improving it – given the unassailability of the realization principle - is to eliminate its accrual (and quasi-accrual) features. Specifically, the agenda is to eliminate...

The proposal aims to simplify the law pertaining to transfers with retained interests and powers under the estate and gift tax that are potentially within current IRC sections 2036-2038. Under the proposal, transfers with retained current-enjoyment interests would be deemed to be incomplete...

The taxable estate is the value of assets at the moment of death or other valuation date. Routine estate planning claims discounts of 30 to 60 percent of the value of the property through temporary, self-imposed restrictions or arrangements that Joseph M. Dodge will lapse or that heirs can undo....