ࡱ> vxstue@ bjbj%% (OO !|2r#r#r#r#r#M$M$M$SUUUUUU$BRlyQ:%M$M$:%:%yr#r#ʕ///:%zr#r#S/:%S///7} r#f# @5*"W<70*xM$"o$/$$M$M$M$yyd/:Income Tax Outline Prof. Buchanan Spring 2007 General SUBSTANCE OVER FORM - pervades the entire tax law HORIZONTAL EQUITY - those with the same ability to pay should pay the same VERTICAL EQUITY those who can pay more, should to the extent means by the amount of (the amount that something exceeds something), not if tax avoidance ( legal try to limit tax liability using reasonable arguments based on the code e.g., partial reimbursement, expenses partially fully deductible and partially half deductible ( claim a full deduction claiming that the partial reimbursement was for the half deductible portion tax evasion ( illegal try to take aggressive positions to play with the words of the code e.g., if you try to deduct as expense something that was reimbursed getting lots of income and not reporting it tax protesters (say they shouldnt have to pay taxes at all) taxes are voluntary BUT voluntary just means that the taxpayer determines the amount rather than have the government doing it 861 position foreign source income is the only income subject to taxation 13th Amendment no slavery, and taxes are akin to slavery 16th Amendment never quite ratified IRS isnt a US agency, its a private agency DC Circuit Murphy held the tax code to be unconstitutional, the panel vacated their own opinion and will rehear the case ( mens rea requirement in criminal proceedings? Sources of Tax Law IRC of 1986 Treasury Regulations very persuasive guidance you can usually view them as certain to be adhered to by courts not updated reliably because Congress changes to codes so frequently Revenue Rulings issued by Treasury staff in response to a fact pattern (can be sent by taxpayers to the IRS) revenue rulings persuasive Private letter rulings binding with respect only to that person somewhat persuasive for everyone else ( theyre published each year Tax litigation IRS has lots of internal remedies internal appeals, etc. ALJs ( almost amazing that anyone ever convicted for evasion original jurisdiction federal district courts, US Tax Court, US Court of Claims (last 2 are Article I courts) Tax Court - Judges are Article I judges (21 or so of them) no lifetime tenure 10-yr. renewable terms reviewable by the Circuit courts (in which the TP resides), and then SCOTUS SCOTUS will probably not resolve circuit splits, and there are lots of splits within the circuits themselves (one time will decide one way, another time another way) Tax Court judge has to look to Circuit law of home base of the taxpayer inconsistent with notion of a court of specialised jurisdiction meant to have expertise District court (jury trials available) ( dont like dealing with technical tax issues (> chance to win?) Fed. Ct. of Claims ( follows Ct. App. for the Fed. Cir., which may be more favorable SoL general ( 3 yrs. from date of return filed ( 6501) if TP omits substantial amount of income ( 6 yrs. ( 6501(e)) fraudulent return or fails to file ( SoL open ( 6501(c)) Double Taxation - taxing the same base twice (or more than once) flow variable ( defined over a passage of time speed only has meaning if you put a time unit on it income is a flow variable - $x per year stock variable ( defined at a moment in time distance wealth is a stock variable tax base item or activity we use to determine tax liability most of the income tax system is designed to prevent double taxation of income employees pay tax on their income, employers tax on their in come (but they get to deduct wages to employees so its not taxed twice) circular flow of goods ( the question is incidence estate tax ( large zero bracket ( but then what would the alternative be, and would it be worse? Behavior tax expenditures a way for government to allow someone to end up with more money than they otherwise would end up with to do something the government wants/encourages them to do if you can label something a tax cut its politically good, as opposed to calling it an expenditure equivalent to things like government subsidies you get same result using different terms incidence who ultimately pays the tax, regardless of who gives the money to the tax collector? can you pass along the tax assessed to others? businesses can raise price, lower wages, etc. ( no tax incidence its an open question as to who bears the incidence implicit taxes if you have different tax treatment people will respond differently e.g. - municipal bonds that interest not taxed but lower interest rate than other taxed bonds Average & Marginal Rates average tax total tax divided by income regressive average tax declines as income increases almost every other units within tax system (state / local) proportional average tax constant as income increases overall taxes in US (except for very lowest bracket but it varies widely) progressive average tax goes up as income increases US system 2004 federal zero bracket = $0 - $22,100 (married joint)( Zero bracket is standard deduction + personal exemptions 1 - marginal rates rate for each additional dollar (there can be a huge different between average rate and marginal rate) Time value of money why people like to defer their taxes to future years quantify savings by determining amount to be set aside in order to have some amount of money in the future Present value = Future value / (1+ r)n r = interest rate n = number of periods deferred rule of 72 calculating how long it takes something to double in value 72/r Key types of calculations Income TaxAMTGross Income (GI) minus above the line deductions (ATLD) = AGI subtract basis for capital gains for GI ATLD (62) (includes things like business deductions, reimbursed expenses of employees, education loan interest, HSAs, higher education expenses,TI + excluded preferences = AMTI preferences 56-58 phaseout of exemption if AMTI over 150,000 (25% of AMTI exceeding 150,000) exemption is reduced by that amountAGI minus personal exemptions ( 151) and the greater of the standard deduction ( 63) or itemized deductions = taxable income (TI) (63) phaseouts of deductions once income high enoughAMTI exemption = taxable excess TI times tax rate (or figure out tax owed on tables) = tax due Capital gains other than short term capital gains (sold within a year) have a different rate for individuals, estates and trusts (but not corporations)Taxable excess * AMT tax rate = tentative minimum tax 26% for first 175,000 28% for excess over 175,000 TD minus any credits for overall tax liabilityTentative minimum tax regular tax paid = AMT (if positive number)Alimony - Excessive FrontloadingBoot & Basis71(f)(4)(B) 10,000 (3rd yr. payment) + 15,000 (statutory amount) = 25,000 71(f)(4)(A) 35,000 (2nd yr. payment) 71(f)(4) 35,000 25,000 = 10,000 (excess payment for 2nd post separation year) 71(f)(3)(B)(i)(I) 35,000 (2nd yr. payment) 10,000 (excess payment for 2nd yr.) = 25,000 71(f)(3)(B)(i)(II) 10,000 (3rd yr. payment) 71(f)(3)(B)(i) average of 25,000 and 10,000 = 17,500 71(f)(3)(B) 17,500 + 15,000 = 32,500 71(f)(3)(A) 75,000 71(f)(3) 32,500 = 42,500 71(f)(2) 10,000 + 42,500 = 52,500 this sum is what the payor spouse adds into income in 3rd year, and payee spouse deducts in 3rd yearA + B = C C D = E A original basis B gain recognized C total basis to be allocated between boot and like-kind property received D portion of basis allocated to boot (its FMV) E new substituted basis of like-kind property received Gross Income - 61 61 gross income means all income from whatever source derived ( unexhaustive list so it ends up being defined by analogy given their inclusions T. Reg. 1.61-1 - adds unless excluded by law presumption is that its income unless there is a positive section that specifically excludes it so you ask 1)is it income? 2) is it excluded by law? Haig-Simons Income income (Y) = fair market value of a person s consumption (C) +  net worth for the year ( property rights ) (S) ( Y = C + S realization requirement is an example of a departure from H-G ideal (as are tax-deferred savings) valuation problem ( a thing might have different values to different people in practice fmv can sometimes be assumed away ( fact question if services rendered for stipulated price, that price is presumed to be fmv unless theres evidence to the contrary (burden shifts to IRS) so always state the price ( undervalue reasonably imputed income and leisure would be included Eisner v. Macomber income is the gain derived from capital, from labor, or from both combined wasnt meant to be exhaustive, but people tried to get out of it a lot Non-Cash Benefits Old Colony Trust p. 41 - 1929 employers payment of employees income taxes constitutes income to employee grossing up Gross pay = Net pay/(1-t) in theory extended to anything paid to employee in compensation for services rendered unless theres a specific exclusion of it Benaglia p. 42 1937 - guy lives in hotel he manages, though he manages 3 properties court finds that room and board are not part of the income ( they were for the convenience of the employer burden of proof is on the taxpayer distinguishing Ralph Kitchen case evidence of them having to be there all the time ( testimony of both employee and employer (even though they both have incentive to go the same way ( self-serving testimony) horizontal and vertical equity ( should they pay less because of the form of compensation, and other people have to pay room and board themselves contract was irrelevant ( only negotiable term was wages wife ( she was probably his partner in some way, doing hostessing type work 119 present post-Benaglia rule (a) room and board not included in GI if for the convenience of the employer for meals, the meals are furnished on the business premises of the employer lodging, employee is required to accept it on the business premises as a condition of employment no longer be subject to self-serving testimony ( mostly a fact-intensive analysis and is not about intent of the parties (119(b)) (b)(4) non-discrimination requirement ( if meals of > half for convenience of employer, all meals furnished for convenience of employr so you cant just benefit all the top guys 119(d)(2) lodging by educational institutions in cases of inadequate rent ( anti-abuse provision see class notes for calculation ( p. 101 statute book, notes p. 7 ambiguous words that leave room for good lawyering (are groceries meals? what is furnished?) convenience of the employer on call outside of working hours what is on the premises employee see J. Grant Farms guy incorporates his farm, employs himself ( house is corporately owned ( employer corporation requires him to live on premises Fringe Benefits medical insurance and payments ( 105(b), 106), group term life insurance ( 79), dependent care assistance ( 129) 132 certain fringe benefits not included in gross income ceasefire in place ( not necessarily horizontally equitable no-additional cost services (a) free services in ordinary line of business of the company and you have to be working in that particular service for it to non-taxable (no incentive to conglomerate) qualified employee discount service specific working condition fringes business use of company car, magazine subscription (job-related) something that if employee paid, they could deduct it under 162 or 167 de minimis fringe if no exclusion, always try to argue this if an eating facility even if amount of money is large ( can still be de minimis if eating facility doesnt make a profit qualified transportation fringe parking, transit cards, certain commuter highway vehicles (at least 6 people, at least seating capacity full) moving expenses, on premises gyms, airline affiliate deals, retirement planning default rule is fair market value ( what you would pay in an arms-length transaction safe harbor provisions tables for making calculations Cafeteria Plans - 125 offers employees a choice between non-taxable fringe benefits or cash (taxable) ( so that those who have non need for it arent stuck with it while other get the benefit of it not horizontally equitable, but it wont necessarily feel wrong to the parties involved permissible benefits include group term life insurance, dependent care assistance, adoption assistance, excludable accident and health benefits, 401(k) contributions use-it-or-lose-it rule unused portions wont be paid out in cash, one can elect to change if theres a change in family status requires good planning ( you may end up paying for stuff you dont want at the end of the year Health Insurance - 105(b), 106 employers are allowed to deduct that they buy for or reimburse to employees (162) benefits received by employees excluded from GI (106(a)) self-employed taxpayers can deduct for cost of medical care (including insurance) as a business expense (162(a)) employees who dont receive employer coverage cannot deduct for medical expenses (unless the cost goes above 7.5% of AGI) (213) Other Income winnings, windfalls Turner p. 60 - won a luxury trip for 2 to Buenos Aires, changed it to a coach trip for 4 to Brasil reported $520, Commissioner said it was $2220 (retail price), court says $1400 ( taxable because it was valuable and they consumed it Ct. says value to TP not the retail cost ( but came up with no reasoned principle as to how to get to the right amount ticket not transferable, other restrictions ( wouldnt have purchased them otherwise worthless as precedent, but remember Ct.s statement about it being a luxury beyond their means that shouldnt be taxed at fmv Rev. Rule 79-24 barter club ( lawyer and house painter exchange services painter gives landlord painting for 6 months of rent 61(a) says barter is income 1.61-2 says fair market value of thing consumed is the income e.g. lawyer reports fmv of painting services received and vice versa in the end it doesnt matter, if FMV werent equal, they wouldnt have done it (theoretically) Glenshaw Glass p. 70 are punitive damages gross income? 61 gains or profits or income derived from any source whatever ( approximates H-G income undeniable accessions to wealth, clearly realized, and over which the taxpayers have complete dominion Congress intent to tax all gains except those specifically exempted Congress meaning should be controlling (as opposed to colloquial meaning, common law meaning) cf. Murphy (talks about what income meant to framers of 16th Amendment) would be an anomaly recovery for actual damages taxable but not additional amount extracted as punishment for the same conduct in personal injury cases 104(a) ( punitives still taxable, but not the compensatory damages it turns out to be sexist ( women tend to pay more taxes than men (emotional distress only if resulting from some other physical injury or sickness) doesnt apply to deductions already taken under 213 basically behind the fact that we tax winnings and windfalls (even found money) ( for treasure trove, it must be declared in the year in which it was discovered and reduced to possession Imputed Income benefits derived from ownership of property or performing own services, also leisure not taxed home ownership, leisure, performing services yourself (could be inefficient if you get paid a lot), human capital (studying law or medicine to be able to earn money in future, but you forgo income while studying) Gambling must include gambling winnings, can be offset by gambling losses (up to amount of gambling winnings) 165(d) Gifts - 102 no income to donee, no deduction to donor ( if other way around, it would provide planning opportunities given the different tax brackets 102 if you receive property as a gift, income derived from property is taxable ( transferred basis in general gifts not taxable employer-employee exception - 102(c) categorical rule ( certain exclusions for employee achievement awards ( 74) (and also small gifts could qualify as 132 de minimis fringe) Duberstein p. 75 - under Duberstein most answers will be maybe president of company received a Cadillac for having referred some potential customers to supplier, president of supplier called it a gift, but that company deducted it as a business expense IRS not gift; TC Not gift, 6th Cir. Gift, they reverse Duberstein TC not clearly erroneous gift with business undertones statute doesnt use gift in common law sense, but in a more colloquial sense (not about consideration or legal or moral obligations), gift for gift tax purposes can be different than gift for income tax purposes a gift in the statutory sense proceeds from a detached and disinterested generosity out of affection, respect, admiration, charity, or like impulses (LoBue) most critical is the transferors intention ( must be an objective inquiry as to their subjective intention super-deference to finders of fact ( but they say maybe finders of fact will be persuaded by similar fact patterns (or Congress can fix it) Stanton joined case, same question ( comptroller or Church corporations, there was possibly some ill-feeling, but they said that it was a gratuity to be paid each month after resignation provided that all rights and claims and retirement benefits released (there were none) IRS Not gift, TC Gift (conclusory opinion), 2nd Cir. - Not gift, they remand just have to give some basic reason why Harris the sisters and the skeazy old man Kritzik ( criminal case so intent is important (mens rea) failure to file and willful evasion his letters ( not hearsay, because offered to show her intent ( she reasonably viewed them as gifts because of his professed love for her (what she thought he thought) also no fair warning given state of law on mistresses ( seems to be income if payment each and every time or if its clearly a brothel should have been done in a civil context ( maybe Duberstein provides enough guidance ( but you cant put someone in jail for it (Duberstein doesnt give people enough notice to know that theyre in violation) Conley - failure to file ( shes only required to file income tax if what she received was income 1) if income, if she knew of her duty to pay taxes, 2) if she knew, did she voluntarily and intentionally violate the duty whats really important is his intent (he paid gift taxes on some of it) ( even if she viewed it as a job, if he viewed it as a gift thats what matters gift tax returns are hearsay they were put in evidence to prove truth of the matter asserted his affidavit Court said he was possibly lying to save his own skin (clear motive to lie) putting him down as employer for bank card ( her intent, not his Tipping - taxable tips for servers fully expected, employers pay less ( its considered for services rendered Regs. 1.61-2(a)(1) they basically report 10% 274(b) business gifts donee doesnt pay taxes on it, business can deduct up to $25 Basis we try to carefully keep track of stuff that has already been taxed ( basis is something you pay Taft v. Bowers p. 96 Chief Justice Taft recused himself donor - $1000 in 1916, gift - $2000 fmv in 1923, sale - $5000 in 1923 donee gets taxed on gain from original cost, not the cost when they received it carryover basis requires donee to stand in shoes of donor as far as basis is concerned if we make donor pay ( worry is forced sales, forced liquidity 16th Amendment doesnt say it can only be taxed against the person to whom the income accrued Carryover Basis - 1015(a) if gain ( basis of recipient is equal to donors basis (original cost) ( original donors basis in case of regifts if loss ( basis of recipient is equal to fmv on date of transfer if in between (above fmv at time of transfer but less than original basis, its neither a gain nor a loss to the donee) 1012 transfer of property as compensation donor pays taxes on realized gain from fmv at time of transfer, donee gets basis at fmv at time of transfer Transfers at Death - 1014 basis shall be fmv on date of death stepped up reason to hold winners you can give it to heirs and it will never be taxed (if they sell it right away before it increases some more), unless its subject to the estate tax stepped down reason to sell losers the estate can deduct the loss may have a bad effect locks in capital (rather than perhaps getting it to the people who would use it best) Timing cash method of accounting must include when actually or constructively received, whichever is earliest (constructively received means offered but chose to defer receipt) accrual method of accounting must include items of income when all the events have occurred that fix the right to receive the income and the amount thereof can be determined with reasonable accuracy Sanford & Brooks p. 126 - dredging company US govt subcontract ( start dredging Delaware River, contract was abandoned ( they hit rock and couldnt dredge $192,577.59 ( $176,271 plus interest recovery from a contract claim won in 1920 in 1920 IRS calls it income, S&B want to call it a recoupment of losses ( amended returns taxpayer loses and must pay taxes even though they never made a profit SCOTUS ( income tax is an annual accounting system ( harsh decision Congress didnt like this case, so they passed 172 you can use any losses from that year to offset income from previous years and gains for future years (with certain limits) but you can only deduct each loss once net operating loss carryback to up to 2 years file an amended return for prior year reducing income for that year by loss carryback ( refund has to be tied to SoL (3 yrs.) net operating loss carryover to up to 20 years any loss not carried back can be used in offsetting income over the next 20 yrs. ( incentive to invest Claim of Right North American Oil Consolidated p. 131 US govt owned land, NAO operating on it (drilling oil) ( NAO wins case in 1922, but in 1917 you get the final decree from district court (US govt cant oust NAO from the land ( profit they receive is profit to them, though presumably theyre paying royalties to US) around $172,000 profits receiver receives in 1916 ( escrow account (earns income during the year) ( in 1917 gives it to NAO in 1917, NAO has control over it ( even though they might have to give it back accrued in 1916, received in 1917 should make a difference whether on accrual or cash basis if partial receivership ( then corporation does taxes ( potential for abuse otherwise if a taxpayer receives earnings under a claim of right and without restriction as to its disposition, he has received income which he is required to [report] return, even though it may still be claimed that he is not entitled to retain the money, and even though he may still be adjudged liable to restore the equivalent US v. Lewis p. 134 employee receives bonus that later must return because there was a mistake taxpayer can deduct the amount the year he finds out it was wrong, but cant amend the return from when he originally receives the money Congress passes 1341 allows taxpayer to choose the more favorable treatment ( they can either deduct it the year they lose it, or they can electively overrule Lewis by amending other return if deduction is over $3000, then TP can reduce tax liability (not income) in the year of repayment by the reduction in tax that would have occurred in the year in which income was included had TP not included that amount (reduction in tax taken in lieu of present deduction), or can take the deduction in the amount repaid Tax Benefit Rule - 111 - loss in earlier year, reversal of loss in later year exclusionary aspect if you had a loss, but you didnt gain any tax benefit from that loss (and carryovers have expired unused) (like if youre in the 0 bracket) ( you dont have to include the restored income in the later year inclusionary aspect if you took a benefit, and the includability or amount of the subsequent offsetting gain is not otherwise clearcut ( income in amount of prior deduction should be included Loans / Discharge of Indebtedness loans are not taxed, its not [H-G or 61] income, its a reshuffling of assets and liabilities Secured collateral Unsecured higher interest rateRecourse lender knows that if they want to get principal back, you personally can be suedLower interest rate Lower interest rateHigher interest rate Lower interest rate Nonrecourse cant be personally suedLower interest rate Higher interest rateHigher interest rate Higher interest rate Kirby Lumber p. 147 1931 issued bonds, then in the same year purchased bonds of face value $1M for $862,000 (so thats $138,000 that they dont have to repay) court says there are long standing treasury regulations that say this is income debt partially forgiven Kerbaugh Empire (decided wrongly) dont think that theres no discharge of debt income if the entire transaction is a loss ( thats just not true 108 Relief insolvent debtors why pile on? income from discharge of indebtedness is excludable ( you still have to give up net operating loss carryovers, but because youre insolvent they wont make you pay taxes on it because you have nothing as it is also available to solvent farmers for qualified farm indebtedness student loan forgiveness ( provided its contingent upon work for a charitable or educational inst. Zarin p. 150 craps addict, unenforceable gambling debt under NJ law Resorts files a lawsuit against Zarin for the $3.4M ( they settle for $500,000 if unenforceable, why did he pay $500,000? liability implies legally enforceable obligation to repay gaming chips are evidence of indebtedness as opposed to property ( concern that chips would start to flow as a separate type of currency in violation of federal law definitions of what indebtedness means either liability (never legally required to pay debt) or property (chips only evidence of debt and property of casino)( 108(d)(1) doesnt apply, and if it does, it all has to come down to contested liability disputed debt or contested liability when theres a good faith dispute over value, then the settlement is the amount of the debt for tax purposes Commissioner says that only works if value is unknown, and it was known majority basically said that all debt is unliquidated because all debt may be contested and could be settled for less ( most scholars major problem with the holding is that ( would mean basically that there is no discharge of debt the fact that they settled at all means that the debt wasnt really 3.4M they said that if unenforceable, the amount is always in dispute Dissent - reason he was allowed not to declare 3.4 M in first place is because it was a debt 108(d)s definition of indebtedness is only for that section, not for 61(a)(12) Gilbert p. 180 illegal income principal stockholder / director of company (Bruce) ( has a money making scheme, unauthorized withdrawals he signs a promissory note to Bruce, securing it by personal property (which more than covered the 2M company funds to over his personal margin call) court says embezzlers know that money is not there and they dont intend to repay (even if they eventually have to repay, its still income so they have to pay taxes on it) embezzlers must declare illegal income, and then when they repay (if ever) they cant deduct it James case said that if embezzled money paid back within the year, then theres no taxable income where a taxpayer withdraws funds from a corporation which he fully intends to repay and which he expects with reasonable certainty he will be able to repay, where he believes his withdrawals will be approved by the corporation, and where he makes a prompt assignment of assets sufficient to secure the amount owed, he does not realize income on the withdrawals under the James case Realization & Recognition / Non-Recognition Home Sales - 121 losses on the sale of a home are not deductible ( so definitely asymmetric treatment sometimes gains are taxable, sometimes not ( when taxed, its taxed as capital gain 250K / 500K (married filing jointly) exclusion ( you want to keep track of every penny you spend both in buying house and in improving the house (which increases basis) if married, if one spouse owns the house, both spouses have to use it for 2 years out of 5 years (it doesnt have to be the same 2 years) has to have been used as a principal residence for 2 of previous 5 years (aggregated total of 2 yrs. out of 5) ( Reg. 1.121-1 totality of evidence test 121(d)(3)(b) if former spouse living there under a divorce decree, the other ex-spouse presumed to be living there only 1 sale or exchange very 2 yrs. - 121(c) ( to prevent house flipping as a business if you dont meet the 2 yr. requirement, you get a proportion of the amount of the exclusion (so if you live there for 6 months, its a quarter of the exclusion) this is if youre selling and moving for change of place of employment, health, or other unforeseen circumstances from regs (there are no regs) Realization whether something of tax significance happened in the 1st place will tax income (from capital) when something important happens, not when accrued practicality ( valuation problems each yr. liquidity / divisibility variation of values (refundability) arbitrariness of accounting period creates behavior distortions ( incentive to sell when assets worth less than basis, lock-in when theres appreciation Nonrecognintion - whether a specific, generally statutory non-recognition rule applies to mandate disregard of realization event allowing further time to pass before levying tax even after realization event Macomber p. 194 1920 - stock, rises in value ( stock dividends (given 50% more stocks, so she owns same proportion overall) cited for concept of realization requirement even though the exact holding (that accumulated value is not income) is incorrect what they say is or is not a realization event: try to say theres a difference between the capital and income from the capital ( that theres income that can be severed from the capital ( which is wrong ( for separate use Court says you can tax income whenever accrued as long as it was realized post 1913 ( its unconstitutional to tax unrealized gains because its taxing property, which you cant do without apportionment among the states (this is not good law anymore) if you look at Macombers situation, none of the reasons for realization is around dissent two functionally equivalent circumstances (paying a dividend and then using that income to purchase more stock) ( one taxed as a realization event and one not the income comes from the fact that the stocks are worth more than when she bought them (which is what IRS was arguing) 305 takes a statutory approach to making realization requirement as part of modern tax law will only tax upon a realization event, no special aspect of stock dividend that makes it a realization event, maybe it just doesnt seem like fair notice now, issuance of stock dividend is taxable if shareholder had an option to receive cash dividend Bruun 1915 ( 99 yr. lease, 1929 ( tenant demolished old building, puts up new building ( difference in value is around $51,000, 1933 ( default, repossession by Bruun IRS wanted to tax it as a realization event in 1933 upon repossession Treasury regs post 1917 support IRS position, but conflicting case law a pure Circuit split (9th Cir. says realization upon construction, 2nd Cir. says no realization until sale) the Court basically overrules the bad part of Macomber (the severable income part) by limiting it to its facts (ordinary dividend v. stock dividend), then holds: realization of a gain need not be in cash gain may occur from exchange of property, payment of taxpayers indebtedness, relief from liability, other profit realized from completion of a transaction fact that the gain is a portion of the value of property received by the taxpayer in the transaction does not negative its realization real holding it is not necessary to recognition of taxable gain that he should be able to sever the improvement begetting the gain from his original capital. If that were necessary, no income could arise from the exchange of property gain realized upon termination of leasehold 109 Congress didnt like the outcome of Bruun (still realization event, nonrecognition treatment) gross income doesnt include income from rent derived by a lessor of real property on the termination of a lease, representing the value of such property attributable to buildings erected or other improvements by the lessee but 1019 upon sale, tax is on gain from original basis to time of sale (carryover basis) you can exclude the income from the year in which the lease is terminated, but then you cant reset the basis if youre not recognizing gain of new improvements and you dont get to transfer the basis, you also dont get to depreciate the improvements either Woodsam p. 211 1922 ( Mrs. Wood buys retail property for $296,400 w/ recourse mortgage attached 1931 ( mortgage increased to $400,000 non-recourse (argues that its like a sale, so basis is now $400,000) 1934 ( retail property transferred to Woodsam, still subject to non-recourse $400,000 mortgage 1943 ( disposition (foreclosure sale) courts reasoning ( no realization, property never disposed of ( shes not merely a renter lots of things she could do that renters wouldnt be able to do ( if value kept going up, she could keep taking mortgages off of it income from property, managing it, she could have just sold it (and she would have taken the gain, not the bank) 1001 ( getting rid of, making over, relinquishment ( she didnt do any of those things to create a taxable event so increasing mortgage and going from recourse to nonrecourse did not change her basis Savings & Loan Crisis a typical S&L balance sheet ( assets = mortgages (secured by underlying properties averaged at about 7% APR), liabilities = deposits (5% APR set by regulation) in the 70s, inflation kicked in (oil shock) ( people no longer satisfied with the 5% rate, because you lose money in buying power terms ( demand for higher savings rates maturity mismatch ( savings rates could be rebargained immediately, but loan rates couldnt ( so S&Ls would have more liabilities than assets Cottage Savings p. 215 - see 1001 S&L banks were in huge trouble through no fault of their own, interest rates had gone up Administrative board came up with a way to allow the banks to recoup their losses by swapping like mortgages importance of the S&L industry, SCOTUS takes the case and distorts the law ( judicial activism Memorandum R-49 ( S&Ls dont have to report losses associated with mortgages that are exchanged for substantially identical mortgages held by other lenders FHLBB says loss is not a loss for balance purposes, but it is a loss for tax purposes disposition of property that has lost value ( so you can recognize that as a loss for tax purposes ( but their financial status was pretty much the same realization principle in 1001(a) incorporates a material difference requirement they defer to the Treasury Regulation ( its a reasonable requirement Treasury regulations and interpretations long continued without substantial change, applying to unamended or substantially reenacted statutes, are deemed to have received congressional approval and have the effect of law the mortgages here were legally distinct entitlements ( so realization if not identical 165 argument ( that Cottage Savings didnt sustain bona fide losses, because they lacked economic substance Court says that argument made in a footnote (so not enough evidence to show that they lacked economic substance), and that case cited is inapposite because Cottage Savings didnt retain any sort of de facto ownership over properties transferred Dissent requirements in Memo R-49 is to ensure that they are substantially similar, yet were calling them materially different? Like-Kind Exchanges - 1031 nonrecognition of gain or loss realized on the exchange of trade or business or investment property for like-kind property that will also be used in TPs trade or business or held for investment not elective ( if met, it applies Reg. 1.1031(a)-2 p. 591 lots of asset classes real property, developed or undeveloped and commercial or residential as like kind ( like-kind refers to the nature or character of the property and not to its grade or quality (as long as it is held for investment, business or trade purposes) even non-simultaneous exchanges can qualify (1031(a)(3) and Reg. 1.1031(k)-1 computer for a printer is like kind under safe harbor provision airplane for a bus is not upon sale, gain is calculated using the basis of property transferred ( 1031(d)) Rev. Rule 82-166 - swapping gold bullion for silver bullion (gold is used as an investment in itself, while silver is an industrial commodity ( so not like kind exchange) doesnt really make sense ( theyre both for investment in real life worth of metal is determined by its metal content, these metals have intrinsically different metals and are used in different ways could argue these propositions either for or against like-kind Jordan Marsh p. 227 department store owned two parcels of land, sold them for 2.3 M, which was 2.5 M less than what they paid, then they leased them for 30 yr. terms, with renewal clauses Commissioner argued like-kind exchange based on Reg. 1.1031(a)-1(c) that leasehold of > 30 yrs. is equivalent of a fee interest Ct. holds that its a sale and not an exchange exchanged fee ownership in property for cash fully equal to the value of the fee, and at the same time executed a rental agreement, at fair market rental value was a change as to the quantum of ownership Congress ultimate intent according to the court sets a really high bar, you immediately recognize gains and losses, and you dont recognize it unless Congress has given a clear statement of when things shouldnt be recognized Boot & Basis - 1031 boot is money and anything else that is not like-kind property given along with the like-kind property in an exchange boot and gain - 1031(b) when you receive boot, you recognize the amount of gain up to the amount of the boot ( you recognize the lesser of the gain realized or the amount of the boot boot and loss - 1031(c) if theres a loss, and theres boot you dont recognize the loss boot and subsequent sale ( basis generally, there is a substituted basis (when no boot present) ( basis = basis in property exchanged ( so that any previously unrealized gain will be recognized when gain is recognized because of boot, basis must be increased so that gain will not be taxed again basis of property exchanged plus gain recognized = total basis in new property of total basis in new property, a portion equal to fmv of boot must be allocated to the boot, remainder allocated to the like-kind property received if property subject to debt, reduction in debt is treated as a cash equivalent, and therefore is considered boot when boot is paid, rather than received amount of boot paid is added to the basis of property exchanged Rev. Rule 84-145 p. 238 commercial airlines had route authorities (ability to fly between certain cities) and they only gave a few out, was very competitive airline industry deregulated, so the route authorities became worth much less airlines had to have separate capital accounts for the money they spent in getting route authorities capitalized costs = the basis, the route authorities were the property just because something you own has become worthless, if you can still use it you havent realized your tax loss yet no completed or closed transaction within the taxable year under 165 Spousal Transfers Davis made a property settlement ( hed give support payments to Mrs. Davis and child ( he transferred stock as full satisfaction and settlement of any and all claims she would have against him and his property tried to argue that it was a division between 2 co-owners, and that they should try to make tax consequences consistent nationally (and that if they interpret it as a taxable event, then it treats community property states differently from a common-law jurisdiction) state laws differ, thats federalism for you Circuit split ( marital rights surrendered presumptively equal to fmv of the property received or marital rights too difficult to value they say its an arms length transaction, so a realization event ( values are presumed to be equal, and the fmv becomes her tax basis Mr. Davis received the fmv of the stock (the release of the inchoate marital rights of Mrs. Davis) ( he has to pay taxes on the gain 1041 - no gain or losses recognized on transfers of property between spouses or incident to a divorce ( substituted basis in the hands of the transferee the carryover basis is used if it is subsequently sold for a gain or a loss (unlike 1015 for gifts, where basis is fmv at transfer if a loss) so who ends up paying the taxes is very different under 1041 and under Davis ( something to plan around its important to have a baseline rule to negotiate around Farid-es-Sultaneh p. 307 1947 antenuptial agreement and basis ex-wife of Kresge (founder of K-Mart) got stock worth a total of $800,000 pursuant to an antenuptial agreement his basis was 0.15 a share, when they got married worth $10 per share, when sold $19 per share IRS tries to say it was a gift, so she would have gotten substituted basis of 0.15 per share logic is a lot like Davis arms-length transaction, she gave up her future marital rights presumptively for fmv of $800,000, so her basis in the stock is that amount but it was her contingent right to sue him, which seems to be worth nothing, so how can that be her basis? what was her basis in the rights (none, because she did nothing for them other than promise to marry him)? whats interesting is that fmv of inchoate marriage rights is totally contingent on the parties involved Alimony, Child Support & Property Settlements alimony (cash payments) 71 & 215 - deduction to payor, income to payee requirements for it to be alimony pursuant to divorce settlement or decree written cash payments only no oral agreements (not a section) must live in separate households must not be for child support (if payments end if child dies or reaches X age, presumed) payment obligation must not continue after death of payee spouse can opt-out in a written agreement can manipulate the tax rates, so that you net more money and reduce the amount of taxes paid ( something they can negotiate over frontloading provisions ( see order of calculation above child support not deductible ( horizontal equity argument, if still married, it would be personal expenses that cant be deducted under 262 same treatment as property settlements ( not deductible to payor or includable as income Diez-Arguelles p. 315 - deadbeat dad, can she call his nonpayment of child support a non business bad debt? she was diligent in trying to collect getting legal decrees saying he has to pay business bad debts ( theyre deductible in the year they become completely worthless, and deductible only to extent of TPs basis in the debt requires a valid and enforceable obligation to pay a fixed or determinable sum of money (Garber) claim which arises out of breach of contract prior to being reduced to judgment doesnt create a debtor-creditor relationship because the injured party has only an unliquidated claim to damages court says no, because she has no basis in the debt ( conceptually wrong, because she paid out post-tax dollars to more than cover his obligation, so it seems like that should be her basis courts attitude of women v. men ( they use her first name, his last name ( they call the children her children legal fees to obtain child support considered to be nondeductible personal expenses (McClendon) Deductions Personal Deductions - 262 ATL deductions - 62 BTL deductions see 63 for treatment, 67 itemized or standard deduction largest itemized are home mortgage interest deduction and state and local taxes deduction itemized other than those listed in 67(b) subject to 2% threshold (including unreimbursed business expenses and most attorneys fees other than unlawful discrimination suits) begin to get phased out if AGI above applicable amount in 68(b) deduction reduced by lesser of 3% of AGI in excess of applicable amount or 80% of itemized deductions personal exemptions ( 151) phaseout of PE for high-income earners ( reduced 2% for every 2500 increment (partial increment treated as full one) of AGI in excess of the threshold phaseout amount topsy-turvy ( the higher bracket youre in, the more a deduction is worth to you (until you start getting phased out) Medical Expenses - 213 can deduct medical expenses that are above the 7.5% of AGI threshold amounts paid for the diagnosis, cure, mitigation, treatment or prevention of disease, or for the purpose of affecting any structure within the body ( very broad amounts spent on improvements to property deductible only to extent they exceed increase in value of the property cosmetic surgery ( to correct a congenital deformity or a deformity arising from injury or disease (213(d)(9)) no deduction for OTC drugs 213(d)(11) ( long term care ( not deductible if for spouse or relative ( but is deductible if provided by a licensed professional (which basically helps the rich who can afford the nurse, and hurts most people who cant afford that) Taylor had to get lawn mowed because of allergies every tax provision has a rule of reason ( this is just unreasonable TPs burden to prove it was a qualified medical expense no evidence that a family member couldnt do it, or that he wouldnt have paid someone to do it without having allergies 262 disallows personal, living and family deductions Court says the 2 are in conflict, and this one falls under 262 ( but 262 disallows deductions subject to any other exceptions from that section in the Code ( and 213 is an exception Henderson kid with spina bifida ( van depreciation as medical expense CPA recommended deducting the van (its depreciation) they did everything right ( tried to get people to take care of him, try to get school district to install a lift in school bus, etc. medical expenses paid ( depreciation isnt an expense paid (so they should have deducted it all in the year that it was purchased) economists will say that depreciation is like slowly buying use of the van ( so in a sense it is an expense paid HSAs 223 - designed to encourage taxpayers to purchase insurance with high annual deductible ( so that people dont go doing frivolous things because its at no cost to them TP must not be covered by Medicare and must have a high deductible health plan and no other health insurance annual deductible not less than $1000 (for individual), $2000 for family and annual combined deductible and out of pocket expenses are not more than $5000, or 10,000 TPs can take an ATL for amounts contributed to HAS and can exclude employer contributions to HAS (but caps monthly and annual contributions) income earned on HAS isnt included in income and distributions not included if used for medical expenses Ochs wife had cancer, sent children away to school they sent kids to boarding school because it cost less than the wife going to some sort of institution the fact that the rest of the family benefits from it, it makes it personal and not-deductible even though it benefits her, which is medical Dissent courts do line drawing all the time, its their job his proposed test - would the taxpayer, considering his income and his living standard, normally spend money in this way regardless of illness? has he enjoyed such luxuries or services in the past? did a competent physician prescribe this specific expense as an indispensable part of treatment? has taxpayer followed the physicians advice in the most economical way possible? are the so-called medical expenses over and above what the patient would have to pay anyway for living expense? Is treatment closely geared to a particular condition and not just to the patients general good health or well-being? Charitable Contributions - 170 & 501 501(c)(3) defines non-profit for the non-profits (tax exempt status); 170 explains when individuals may deduct ( perfect overlap for our purposes notion that money donated to charity is not done for consumption individuals who pay for charities relieve the government for expenses it would otherwise be forced to bear deduction is a proper incentive (rewarding socially useful behavior) what qualifies as charitable organization? US, state or local govt entity charitable corp., trust, community chest, etc. if operated exclusively for religious, charitable, scientific, literary, or educational purposes, to foster natl or intl amateur sports, or for the prevention of cruelty to children or animals fraternal order or lodge, only if gift to be used exclusively for charitable purposes war veterans org. or non-profit cemetery co. not deductible if any part of net earnings of donee org. benefit any private shareholder or individual or if it attempts to influence legislation or political campaigns if donation to university, and gives donor a right to buy preferred seating tickets for athletic events ( deduction limited to 80% of contributions fixed payments to churches, synagogues, etc. are deductible (except Scientology training and auditing which was subject to payment schedules ( later position reversed by IRS) if contribute services, no 170 deduction (unreimbursed expenses deductible) 170(b)(1)(A),(B) and (2) limits amount of contributions (usually percentage of AGI), but excess may be carried forward up to 5 yrs. property fmv, with limits (if short-term capital asset or not a capital asset (like a painting), then deduction is adjusted basis) even if long term capital gain, still limited to adjusted basis if tangible personal property whose use unrelated to charitable orgs purpose, property donated to certain private orgs, or if its a patent or other IP if not limited by above, itll probably still be limited to a percentage of AGI (170(b)(1)(C)(i) valuation of appreciated property often litigated ( they try to inflate the value penalty for overvaluation - 6662 substantiation requirements Ottawa Silica Company was a silica mining company but had begun buying land as a land speculator, gives a strategic stretch of land to a local High School, will lead to creation of an access road that the Company can use cannot deduct if the donor receives a substantial (rather than incidental) benefit from donating Substantial means that donors benefit is greater than the benefit to general public DuVal (1994) p. 372: Tax Court stresses objective element of determining donor intent We must make an objective inquiry into the nature of the transaction to determine whether what is labeled a gift is in substance a gift Quid pro quo contributions: A taxpayer can only deduct the money donated that exceeds the FMV of whatever she receives in return Bob Jones University religious organization that believed (sincerely) that the Bible prohibits inter-racial marriage - can they discriminate in admissions policy and still be tax-exempt organization? Students are expelled for dating out of their race or for advocating against these prohibitions Rev Ruling 71-447 states explicitly that a 501(c)(3) cannot operate in a way which is contrary to public policy 170 & 501 incorporate a public policy component and prohibit tax-exempt status from any non-profit organization which operates in a manner which is contrary to public policy Congress had many opportunities to clarify the law or to overrule IRS actions but it did not overturn what IRS did IRS policy does not violate Free Exercise Clause or Establishment Clause if the tax-exempt status thought of as a subsidy, then Brown v. Board is dispositive (publicly funded educational institutions cant discriminate on account of race) ( but the court cant go there, because if its a subsidy then that would violate the Establishment Clause has been limited to its facts - an educational institution can be denied tax-exempt status if it racially discriminates It has not been used to deny tax-exempt status to many other organizations Personal Circumstances EITC - 32 only for working poor ( its a wage subsidy like a negative tax amount credit exceeds tax liability is refundable but as you get phased out, theres a disincentive to work, because you start getting taxed more and you start to lose your credits, so you can end up with a really high effective tax rate and be worse off than you would have been without working credit for elderly and permanently and totally disabled credit for adoption expenses child tax credit Mixed Business and Personal Outlays Business Deductions & Attorneys Fees 162 - you can deduct money you spent in order to make money (simply not part of what 262 is about) for both businesses and individuals deduction of all the ordinary and necessary expenses paid or incurred in carrying on any trade or business including salaries, traveling expenses, rentals, (but not illegal bribes, etc., money spent to influence legislation except local legislation), health insurance, etc. same logic as basis ( if you spend something, its a cost that you have to deduct from revenue in order to get profit the way 162 fits into the code is odd ( seems to imply that any money you receive is income, and that you can only deduct things the code says you can deduct but income is revenues minus costs ( so why should 162 even exist Buchanan thinks it should just be considered an anti-abuse provision, because of the ordinary and necessary language 212 - expenses for production of income for individuals (businesses cant use this) seems to contain the language of 162(a) 212 seems to be limited to things like financial investment ( not trade or business 67 limited to individuals deductions under 162 and 212 only allowable to the extent that they exceed 2% of AGI (in the aggregate) Attorneys fees - treat attorneys fees as part of the settlement, and the entire settlement is considered to be gross income ATL deduction for certain unlawful discrimination cases (62(a)(20)) AMT ( will usually eliminate possibility of deducting ( can often end up being greater than 100% marginal tax rate ( people winning lawsuits ending up worse off than had they not brought the lawsuit Banks and Banaitis - SCOTUS came up with this weird thing about whether or not you have dominion over the entire amount of the recoveries dicta leaves open possibility of  cutting 2 checks Davenport Position (on attorneys fees) - as a matter of tax theory attorneys fees aren t income same underlying structure under 162 and for basis? sheer profit ( without the lawyer, you never get the income in the first place Nickerson wanted to be dairy farmers 183 limits availability of deductions if that activity is not engaged in for profit (hobby) to deductions to offset income from that activity (cf. gambling) in order to show that they dont fall under 183, they must have a bona fide expectation of making a profit (as opposed to a reasonable expectation) Congress has presumption (safe-harbor) ( profit in 3 out of last 5 years gives you a presumption ( otherwise burden is on the taxpayer to prove that there was really a profit motive anti-abuse provision ( generally applied to high income passive investors Treasury Reg. for 183 - balancing a number of factors that deal with profit motive objective assessment of somebodys state of mind manner in which the taxpayer carries on the activity expertise of the taxpayer (or trying to get some expertise) time and effort expended expectation that assets used in activity may appreciate in value taxpayers history of income or losses amount of occasional profits financial status of the taxpayer elements of personal pleasure or recreation standard of review is clearly erroneous because they were conclusions of facts ( so Buchanan thinks that Tax Court should be upheld common sense dictates that people dont perform manual labor for the fun of it subtle burden shift ( nothing in the record shows that theres an alternative explanation for Nickersons actions Popov professional violinist in a 1-BR apt. 280A covers both vacation homes and home offices deduction for a home office that is exclusively used as the principal place of business for any trade or business of the taxpayer Soliman two considerations for determining if its the principal place of business the relative importance of the activities performed at each location place where goods or services delivered must be given great weight (but musical performance not classified well as a service) time spent at each location a professional musician is allowed to deduct expenses from portion of home used exclusively for musical practice Drucker 2d Cir. similar outcome and they only had one employer was the focal point of their employment related activities (focal point test may no longer be valid post Soliman) Henderson wanted to deduct her plants as office decoration whether a sufficient nexus exists between the expenses and the carrying on of trade or business, or whether they were in essence personal or living expenses where both 162 and 262 may apply, 262 takes precedence Rudolph insurance dealers trip to NYC holding of this case is that there never was a case in SCOTUS ( cert. improvidently granted outside of the 5th Cir., there is no precedential value (just persuasive authority) Harlan writes an opinion anyways, because there were 2 dissenters as far as we can tell, the wives are employees, though just not compensated for it ( insurance co. corresponds with wives telling them how they can help their husbands cos state of mind is required for the question what is income? ( Rudolphs state of mind required for is it deductible? was purpose of trip related primarily to business or was it primarily personal in nature argument about being an organization man ( Court doesnt discuss, no evidence of compulsion 274 additional rules for travel and entertainment deduction for things generally considered to be entertainment, amusement, or recreation only if the activity is directly related to business, or if they are associated with business and directly precede or follow a substantial and bona fide business discussion 274(n) limits otherwise allowable deduction for meals and entertainment to 50% of the cost (because of horizontal equity ( other people have to pay for their meals) 274(m)(3) no deduction for spouse unless the spouse is an employee, spouse has a bona fide business purpose for going on the trip, and the additional expenses would otherwise be deductible 274(d) substantiation ( amount time and place, business purpose of expense, business relationship to person entertained or donee foreign travel ( if partly for personal pleasure, airfare partially disallowed rules for cruises and foreign conventions Danville Plywood p. 443 - Super Bowl trip for clients and some employees some wives, kids and shareholder question here is not deductibility to the employee, its the deductibility to the employer must meet 162, and then if that fits, must look at 274 Ct. decided it doesnt meet 162 1.162-2 ( puts some teeth behind the notion of a facts and circumstances test bright line rule against wives to qualify as an ordinary and necessary business expense under 162(a), an expenditure must be both common and accepted in the community of which TP is a part as well as appropriate for the development of business only traveling expenses which are reasonable and necessary to the conduct of TPs business and which are directly attributable to it may be deducted key facts that if changed could go the other way ( travel agency that set up the trip not told it was for business, no big presentation, etc. Knetsch tax shelters ( substance not form ( loan to buy annuities (from same company), pay all the interest up front but borrow against the income (2.5% income) from annuities ( got a tax saving of $110,000 (and was out of pocket $40,000) for one year, and he did it for 2 years (out of pocket expenses would be the fee to the insurance company for providing the faade) not taking account of tax consequences, no one would do this the return isnt taxable, but the interest payment is deductible its all about substance over form ( have to look past taxpayers argument that it was a loan AMT 55-58 things arent indexed to inflation ( numbers changed on an ad hoc basis annually currently exemption for couples is 62,550, single 42,500 then its a nearly flat rate structure ( changes at $175,000 from 26% to 28% purpose ( to prevent high income tax payers from paying little to no tax concern that the things that allow people to reduce their tax bills arent really tied to reality ( enough is enough problem is that the decision to limit certain tax preferences is itself dictated by politics take your taxable income and add things back in and get AMTI standard deduction and personal exemptions (belief that its a part of big 0 bracket), limiting medical expenses, interest on home equity loans, certain business outlays state and local taxes ( big red state / blue state divide lots of people werent getting hit by AMT before (because regular tax more than AMT), and now they are hit by AMT (so even though regular taxes gone down, theres still a negative connotation to it) Klaassen p. 591 - 10 children, no personal exemptions for AMT easy case ( statutes are specific and unambiguous, those deductions and preferences get added back in policy argument ( Congress probably didnt intend to get people in their situation Congress aware of issue and chooses not to act ( cf. 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