ATA Journal of Legal Tax Research http://scitation.aip.org/ ATA Journal of Legal Tax Research Additional Journal Content http://link.aip.org/link/?LTR/8/i/1&agg=rss <br/> Abstract not available. [The ATA Journal of Legal Tax Research 8, i (2010)] published Wed Jul 21, 2010. An Analysis of IRS Concerns with Conservation Easement Charitable Deductions http://link.aip.org/link/?LTR/8/18/1&agg=rss Kenton D. Swift<br/> ABSTRACT: Over the past 30 years conservation easements have become an increasingly popular tool available to private landowners for protecting endangered natural areas, scenic properties, and working farms and forests. In addition, the charitable contribution deduction allowed for qualified conserv ... [The ATA Journal of Legal Tax Research 8, 18 (2010)] published Wed Jul 21, 2010. Anatomy of a State/Tribal Tax Dispute: Legal Formalism, Shifting Incidence, Potatoes, and the Idaho Motor Fuel Tax http://link.aip.org/link/?LTR/8/1/1&agg=rss Mark J. Cowan<br/> ABSTRACT: The law regarding state taxation in Indian country is one of the last bastions of legal formalism in tax law jurisprudence. The ability of a state to tax in Indian country turns on the legal incidence of the tax: in general, a tax on the tribe or tribal members is not allowed; a tax on non ... [The ATA Journal of Legal Tax Research 8, 1 (2010)] published Wed Jul 21, 2010. Editorial Policy and Style Information http://link.aip.org/link/?LTR/7/vii/1&agg=rss <br/> Abstract not available. [The ATA Journal of Legal Tax Research 7, vii (2009)] published Wed Jul 15, 2009. Additional Journal Content http://link.aip.org/link/?LTR/7/i/1&agg=rss <br/> Abstract not available. [The ATA Journal of Legal Tax Research 7, i (2009)] published Wed Jul 15, 2009. Tax Relief, or Lack Thereof, for the Long-Term Care Costs of the Aging Population in America http://link.aip.org/link/?LTR/7/99/1&agg=rss Cynthia Blanthorne and Mark M. Higgins<br/> ABSTRACT: As the health and longevity of Americans continue to improve, adult children caring for aging parentspossibly at the same time as raising children of their ownis becoming a national phenomenon. This paper examines current and proposed income tax relief for taxpayers who provide financial s ... [The ATA Journal of Legal Tax Research 7, 99 (2009)] published Wed Jul 15, 2009. Child Tax Credit in Divorced Families http://link.aip.org/link/?LTR/7/90/1&agg=rss Valrie Chambers and Anthony P. Curatola<br/> ABSTRACT: For more than 50 years, Congress has responded to the needs of families with various tax breaks ranging from exemptions, the adoption of Head of Household status, Child and Dependent Care Credit, increased Earned Income Credit (EIC) for those with dependent children, and the Child Tax Cred ... [The ATA Journal of Legal Tax Research 7, 90 (2009)] published Wed Jul 15, 2009. A Comparison of the New U.S. Expatriation Tax and the Canadian Departure Tax http://link.aip.org/link/?LTR/7/76/1&agg=rss Alexander M. G. Gelardi<br/> ABSTRACT: The Heroes Earnings Assistance and Relief Tax Act of 2008 amended the anti-avoidance provisions of the Internal Revenue Code for an expatriating taxpayer. The new law requires expatriating taxpayers to report a deemed taxable sale and repurchase of assets at the time that they expatriate. ... [The ATA Journal of Legal Tax Research 7, 76 (2009)] published Wed Jul 15, 2009. Lord of the Rings Impact on Federal and State Film Industry Tax Incentives and Their Tax Treatment http://link.aip.org/link/?LTR/7/57/1&agg=rss Kathleen K. Wright, Stewart S. Karlinsky, and Kim A. Tarantino<br/> ABSTRACT: This article discusses recent developments for both federal and state tax purposes that directly impact the entertainment industry. For federal purposes, Congress has recently expanded the scope of the Section 181 and 199 deductions to allow more generous deductions, and in the case of Sec ... [The ATA Journal of Legal Tax Research 7, 57 (2009)] published Wed Jul 15, 2009. The Existence of Reasonable Doubt as to Revenue Collection and Expense Payment: Implications for Accrual Basis Taxpayers http://link.aip.org/link/?LTR/7/33/1&agg=rss Robert E. Blatz, Jr. and Kirk L. Philipich<br/> One of the basic assumptions of accrual accounting is that, in due time, revenue earned in the normal course of business will be collected and liabilities incurred will be paid. Yet, case law indicates that it is inappropriate to impose the income tax on amounts whose collection is reasonably in dou ... [The ATA Journal of Legal Tax Research 7, 33 (2009)] published Wed Jul 15, 2009. Uncertain Tax Positions: Reconciling the Existing Guidance http://link.aip.org/link/?LTR/7/121/1&agg=rss Steve L. Gill, Damon M. Fleming, and G. E. Whittenburg<br/> ABSTRACT: Multiple revisions in recent years to IRC 6694, IRC 6662, U.S. Generally Accepted Accounting Principles (GAAP), and International Financial Reporting Standards (IFRS) have created conflicting recognition and disclosure requirements for uncertain tax positions. This paper reviews the existi ... [The ATA Journal of Legal Tax Research 7, 121 (2009)] published Wed Jul 15, 2009. Examining Tax Strategy PatentsAn Analysis of Reform Measures http://link.aip.org/link/?LTR/7/16/1&agg=rss Evelyn McDowell and Pamela C. Smith<br/> Tax strategy patents (TSPs) are currently the center of debate due to their potential to monopolize interpretations of the tax code. Current legislative efforts to calm the debate surrounding tax strategy patents fail to do so. This paper analyzes current legislative reform measures aimed at TSPs. W ... [The ATA Journal of Legal Tax Research 7, 16 (2008)] published Fri Dec 12, 2008. When Worlds Collide: Applying the Nonobviousness and Novelty Requirements of Patent Law to Tax Strategy Patents http://link.aip.org/link/?LTR/7/1/1&agg=rss Roby B. Sawyers, David L. Baumer, and Wade M. Chumney<br/> A proliferation of newly issued tax-related patents has resulted in concern and confusion among tax practitioners. Tax practitioners argue that the tax strategies claimed in the patents have been used for many years and do not meet the novel and nonobvious requirements of patent law. Additionally, t ... [The ATA Journal of Legal Tax Research 7, 1 (2008)] published Fri Dec 12, 2008. Editorial Policy and Style Information for The ATA Journal of Legal Tax Research http://link.aip.org/link/?LTR/6/viii/1&agg=rss <br/> Abstract not available. [The ATA Journal of Legal Tax Research 6, viii (2008)] published Tue Oct 21, 2008. Additional Journal Content http://link.aip.org/link/?LTR/6/i/1&agg=rss <br/> Abstract not available. [The ATA Journal of Legal Tax Research 6, i (2008)] published Tue Oct 21, 2008. Passive Rental Activity Issues Challenged in the Tax Court and on Appeal 20002006 http://link.aip.org/link/?LTR/6/62/1&agg=rss Diane A. Riordan and Michael P. Riordan<br/> Section 469 of the Internal Revenue Code limiting the current deduction of passive losses was introduced by the Tax Reform Act of 1986 in response to concerns that rental properties and other investments were acting as tax shelters for the rich. Application of the provision has resulted in a dynamic ... [The ATA Journal of Legal Tax Research 6, 62 (2008)] published Tue Oct 21, 2008. Compensatory Damage Awards for Nonphysical Personal Injuries: The Murphy Pendulum http://link.aip.org/link/?LTR/6/43/1&agg=rss Dennis J. Gaffney, Maureen H. Smith-Gaffney, Richard P. Weber, and Richard O. Davis<br/> The Murphy case involves the question of whether compensatory damage awards received for nonphysical personal injury are subject to the federal income tax. Such awards had been excluded from a taxpayer's gross income since 1918, but in 1996, Congress amended I.R.C. Sec. 104(a)(2) with the intention ... [The ATA Journal of Legal Tax Research 6, 43 (2008)] published Tue Oct 21, 2008. Criminal Prosecution of Tax Return Preparers http://link.aip.org/link/?LTR/6/24/1&agg=rss Nancy B. Nichols<br/> Over 61 percent of individual taxpayers, accounting for more than 76 million returns, utilized the services of paid preparers in 2005. However, hiring a paid preparer does not assure the taxpayer or the government that the return will be prepared correctly. Tax return preparer fraud generally involv ... [The ATA Journal of Legal Tax Research 6, 24 (2008)] published Tue Oct 21, 2008. Should it Take an Act of Congress to Change an Asset's Depreciable Recovery Period? http://link.aip.org/link/?LTR/6/11/1&agg=rss Richard S. Leaman and John C. Tripp<br/> As a result of enacting the Technical and Miscellaneous Revenue Act of 1988, Congress took control of establishing and changing asset depreciation periods from the Treasury Department. A detailed example of changing an asset's recovery period by the legislative process is presented, as well as a det ... [The ATA Journal of Legal Tax Research 6, 11 (2008)] published Tue Oct 21, 2008. Substantiating the Worthless Securities Deduction http://link.aip.org/link/?LTR/6/1/1&agg=rss Andrew J. Judd<br/> The Internal Revenue Code generally provides for the deductibility of economic losses incurred by taxpayers in for-profit transactions. 165(g) specifically allows the deduction of losses associated with securities that become worthless. Unfortunately, neither Congress nor Treasury have articulated ... [The ATA Journal of Legal Tax Research 6, 1 (2008)] published Tue Oct 21, 2008. Additional Journal Content http://link.aip.org/link/?LTR/5/i/1&agg=rss <br/> Abstract not available. [The ATA Journal of Legal Tax Research 5, i (2008)] published Thu Oct 9, 2008.