Matthew A. Melone A LEG TO STAND ON: IS THERE A LEGAL AND PRUDENTIAL SOLUTION TO THE PROBLEM OF TAXPAYER STANDING IN THE FEDERAL TAX CONTEXT? 9 Pittsburgh Tax Review 97 (Spring, 2012) I should be sorry to think that, if a wrong has been done, the plaintiff is to go without a remedy simply because no one can find a peg to hang it on. Lord Justice Denning On September 30, 2008, in the midst of the financial crisis, the Internal Revenue Service (I.R.S.) released Notice 2008-83. Unusual times call for unusual measures, and this... 2012
Lawrence Zelenak CUSTOM AND THE RULE OF LAW IN THE ADMINISTRATION OF THE INCOME TAX 62 Duke Law Journal 829 (December, 2012) From the early years of the federal income tax to the present, the Internal Revenue Service (IRS) has engaged in what might be termed customary deviations from the dictates of the Internal Revenue Code, always in a taxpayer-favorable direction. A prominent current example is the IRS's don't ask, don't tell policy with respect to... 2012
J. Clifton Fleming, Jr. , Robert J. Peroni , Stephen E. Shay DESIGNING A U.S. EXEMPTION SYSTEM FOR FOREIGN INCOME WHEN THE TREASURY IS EMPTY 13 Florida Tax Review 397 (2012) I. Introduction. 398 II. The Double Taxation Conundrum. 401 III. The International Law Solution. 402 IV. Flirting With a Flawed Territoriality. 403 V. Going Territorial in the Midst of a Current and Long-Run Fiscal Crisis. 406 A. Dimensions of the Crisis. 406 B. Forfeiting the Residual Tax. 408 C. Gaining Revenue by Switching to a Zero Rate. 410 D.... 2012
Stephen J. Lubben DO EMPIRICAL BANKRUPTCY STUDIES MATTER? 20 American Bankruptcy Institute Law Review 715 (Winter 2012) It is with great hesitation that I write the above title. After all, in doing so I question my own existence. Nonetheless, in the decades since the current Bankruptcy Code was enacted empirical studies of the process, on both the business and personal side, have been legion. The actual effects on bankruptcy as codified have been slight. Indeed, one... 2012
Jonathan Remy Nash , Rafael I. Pardo DOES IDEOLOGY MATTER IN BANKRUPTCY? VOTING BEHAVIOR ON THE COURTS OF APPEALS 53 William and Mary Law Review 919 (January, 2012) This Article empirically examines whether courts of appeals judges cast ideological votes in the bankruptcy context. The empirical study is unique insofar as it is the first to examine the voting behavior of circuit court judges in bankruptcy cases. More importantly, it focuses on a particular type of dispute that arises in bankruptcy:... 2012
James A. Davids ENFORCING A TRADITIONAL MORAL CODE DOES NOT TRIGGER A RELIGIOUS INSTITUTION'S LOSS OF TAX EXEMPTION 24 Regent University Law Review 433 (2011-2012) In the article to which this paper responds, Mr. Austin Caster appears to make the following arguments: First, tax-exempt, religious organizations that terminate the employment of LGBT workers on the basis of sexual orientation violate public policy and, therefore, should lose their tax exempt status; second, the constitutional protection provided... 2012
Laura Jelinek EQUITY FOR BRAND EQUITY: THE CASE FOR PROTECTING TRADEMARK LICENSEES IN LICENSOR BANKRUPTCIES 40 AIPLA Quarterly Journal 365 (Summer, 2012) I. Introduction. 367 II. The General Treatment of Licensees in Licensor Bankruptcies: Principles and Rules. 368 A. The Bankruptcy Act: Basic Principles and Procedures. 369 1. Bankruptcy Reform Act of 1978. 369 2. The Bankruptcy Proceedings Most Relevant to Intellectual Property Licensors and Licensees: Chapters Eleven and Seven. 370 3. Overview of... 2012
Peter D. Enrich FEDERAL COURTS AND STATE TAXES: SOME JURISDICTIONAL ISSUES, WITH SPECIAL ATTENTION TO THE TAX INJUNCTION ACT 65 Tax Lawyer 731 (Summer, 2012) Typically, controversies concerning state and local taxes are litigated in the state courts. But for a variety of reasons, one of the parties to such a controversy may prefer to litigate in the federal courts. While there are several familiar grounds for federal jurisdiction over such cases, a range of procedural obstacles will confront many... 2012
Daniel M. Reach FITNESS TAX CREDITS: COSTS, BENEFITS, AND VIABILITY 7 Northwestern Journal of Law & Social Policy 352 (Spring, 2012) As the number of overweight and obese Americans rises, it becomes increasingly clear that Americans need further incentives to stimulate lasting lifestyle changes. Tax incentives focused on exercise, which have been largely unexplored to this point, are an effective response to the growing obesity problem in the United States that would largely... 2012
Shu-Yi Oei GETTING MORE BY ASKING LESS: JUSTIFYING AND REFORMING TAX LAW'S OFFER-IN-COMPROMISE PROCEDURE 160 University of Pennsylvania Law Review 1071 (March, 2012) The Offer in Compromise (OIC) is a procedure by which the IRS may agree to forgive a portion of the tax liabilities of certain taxpayers. This Article suggests a framework for evaluating the effectiveness of any proposed reforms to this procedure. It presents three arguments that support forgiving tax debts through devices such as the OIC. These... 2012
Anthony C. Infanti LGBT TAXPAYERS: A COLLISION OF "OTHERS" 13 Georgetown Journal of Gender and the Law 1 (2012) In this symposium, we are spending a day exploring the intersection of tax, gender, and sexuality. When the prominent critical race theorist Kimberle Crenshaw coined the term intersectionality more than twenty years ago, it appears that she had the metaphor of a crossroads in mind. Indeed, when describing how Black women are multiply... 2012
Patrick T. Gillen OPPRESSIVE TAXATION: ABUSE OF RULE 54 AND SECTION 1920 THREATENS JUSTICE 58 Wayne Law Review 235 (Summer, 2012) I. Discovery and Discovery Costs Under the Federal Rules. 238 A. The Structure of the Federal Rules. 239 B. The Language of the Federal Rules Relating to Discovery. 240 C. Recovery of the Costs Incurred to Comply with Discovery Obligations. 241 D. Cost Recovery Under Rule 54(d) and 28 U.S.C.A. § 1920. 243 II. Courts Are Taxing Discover Costs Under... 2012
Jason M. Brown PATENT BOX TAXATION: A COMPARISON OF FOUR RECENT EUROPEAN PATENT BOX TAX REGIMES AND AN ANALYTICAL CONSIDERATION OF IF AND HOW THE UNITED STATES SHOULD IMPLEMENT ITS OWN PATENT BOX 46 International Lawyer 913 (Fall 2012) As the global economy is increasingly driven by the commercialization of highly mobile assets, several European governments have sought to encourage investment in and retention of such assets within their domestic borders by offering heavily incentivized tax rates on profits derived from patents and other highly mobile assets. Notable among the... 2012
Hedda Leikvang PIERCING THE VEIL OF SECRECY: SECURING EFFECTIVE EXCHANGE OF INFORMATION TO REMEDY THE HARMFUL EFFECTS OF TAX HAVENS 45 Vanderbilt Journal of Transnational Law 293 (January, 2012) The enforcement of tax laws abroad has long posed problems for authorities. However, that enforcement becomes increasingly more problematic when the information necessary for proper enforcement is located within an impenetrable system whose sole purpose is to protect that information from tax authorities in other countries. Although much effort has... 2012
Alexander Hogan PROTECTING NATIVE AMERICAN COMMUNITIES BY PRESERVING SOVEREIGN IMMUNITY AND DETERMINING THE PLACE OF TRIBAL BUSINESSES IN THE FEDERAL BANKRUPTCY CODE 43 Columbia Human Rights Law Review 569 (Spring, 2012) Revenues raised through Native American enterprises provide crucial support to the Native American communities in which these businesses are located. In particular, many tribes depend upon Indian casino gaming revenues to fund health care, child care, emergency services (police, fire, and ambulance), educational assistance programs, cultural... 2012
Jean Braucher , Dov Cohen , Robert M. Lawless RACE DISPARITY IN BANKRUPTCY CHAPTER CHOICE AND THE ROLE OF DEBTORS' ATTORNEYS 20 American Bankruptcy Institute Law Review 611 (Winter 2012) We are grateful for the attention the American Bankruptcy Institute Law Review is giving to our research concerning racial disparity in bankruptcy chapter choice and the role debtors' lawyers may play in producing it. We believe that all players in the consumer bankruptcy system should be concerned about just results in the system in general and... 2012
A. Mechele Dickerson RACIAL STEERING IN BANKRUPTCY 20 American Bankruptcy Institute Law Review 623 (Winter 2012) Race, Attorney Influence, and Bankruptcy Chapter Choice presents findings that are extraordinary, yet totally predictable. Those findings: though black debtors are disproportionately placed in chapter 13 (which is more expensive and more burdensome than chapter 7), bankruptcy lawyers steer whites away from chapter 13. Why would I label these... 2012
Jean Braucher , Dov Cohen , Robert M. Lawless REFLECTIONS ON THE RESPONSES TO "RACE, ATTORNEY INFLUENCE, AND BANKRUPTCY CHAPTER CHOICE" 20 American Bankruptcy Institute Law Review 725 (Winter 2012) When we were working on the research that eventually would be published as Race, Attorney Influence, and Bankruptcy Chapter Choice in the Journal of Empirical Legal Studies, we knew we were dealing with a potentially explosive subject matter. As Professor Mechele Dickerson points out in her contribution to this symposium, even persons who view... 2012
Stephanie M. Wildman , Margalynne Armstrong , Beverly Moran REVISITING THE WORK WE KNOW SO LITTLE ABOUT: RACE, WEALTH, PRIVILEGE, AND SOCIAL JUSTICE 2 UC Irvine Law Review 1011 (December, 2012) In his article, The Work We Know So Little About, Gerald López introduces Maria Elena, a housekeeper, mother, tutor, seamstress, and cook. He connects her daily life struggles to make ends meet, to care for her family, and to survive with the issue of social justice for all members of society. He underlines the gap between such clients and legal... 2012
Nicholas P. Cafardi SAVING THE PREACHERS: THE TAX CODE'S PROHIBITION ON CHURCH ELECTIONEERING 50 Duquesne Law Review 503 (Summer, 2012) I. Introduction. 503 II. History. 504 A. Origin of the Prohibition. 504 B. Constitutional Challenges. 507 C. The Effect of the Religious Freedom Restoration Act (RFRA). 508 D. Ongoing Constitutional Analysis. 523 III. Tax Exemption as a Subsidy. 525 IV. IRS Policing of the Church Electioneering Prohibition. 530 A. Cases. 530 B. Other IRS Policing... 2012
David L. Perechocky SHOULD AD HOC COMMITTEES HAVE FIDUCIARY DUTIES?: JUDICIAL REGULATION OF THE BANKRUPTCY MARKET 86 American Bankruptcy Law Journal 527 (Fall 2012) This article is the first to substantively and directly address the question of whether informal creditor groups in bankruptcy cases could and should have fiduciary duties to other creditors. The rise of activist investors and claims traders in bankruptcy proceedings has significantly changed the bankruptcy process, to much controversy. One... 2012
Richard M. Hynes STATE DEFAULT AND SYNTHETIC BANKRUPTCY 87 Washington Law Review 657 (October, 2012) An insolvent state does not need bankruptcy if sovereign immunity would protect it from lawsuits and other collection efforts. To the extent that a state is not judgment-proof and needs bankruptcy, we may not need to modify the Federal Bankruptcy Code to allow it to file. First, a substantial share of state spending flows through their... 2012
David A. Skeel Jr STATES OF BANKRUPTCY 79 University of Chicago Law Review 677 (Spring 2012) In the past several years, many states' financial condition have been so precarious that some observers have predicted that one or more might default. As the crisis persisted, a very unlikely word crept into these conversations: bankruptcy. Should Congress provide a bankruptcy option for states, or would bankruptcy be a mistake? The goal of this... 2012
Dorothy A. Brown TALES FROM A TAX CRIT 10 Pittsburgh Tax Review 47 (Fall, 2012) I would like to thank the Dean and the Seton Hall faculty, especially Tracy Kaye for hosting this year's Critical Tax Conference and inviting me to give today's keynote address. I haven't been to a Critical Tax Conference since April 2005 when I was called a shill for Karl Rove. . . . But I'm getting ahead of my story. I want to take us back in... 2012
Anthony C. Infanti TAX REFORM DISCOURSE 32 Virginia Tax Review 205 (Summer, 2012) Any measure that values a gun several hundred times more than a bottle of milk is bound to raise serious questions about its relevance for human progress. It is no surprise, then, that since the emergence of national income accounts, there has been considerable dissatisfaction with gross national product as a measure of human welfare. GNP reflects... 2012
Alan Simpson TAXATION OF NON-RESIDENT ENTERTAINERS AND SPORTSMEN: THE UNITED KINGDOM'S DEFINITION OF PERFORMANCE INCOME AND HOW IT OUGHT TO BE MEASURED 11 Washington University Global Studies Law Review 693 (2012) Track and field star Usain Bolt recently boycotted a race in the United Kingdom because of the severe income tax implications that would result from his performance. The United Kingdom's current interpretation of their taxing statute was established by a line of cases involving tennis star Andre Agassi and his company, Agassi Enterprises, Inc.... 2012
Matthew A. Melone TAXPAYERS' CHALLENGES TO FAVORABLE IRS GUIDANCE 89 Practical Tax Strategies 266 (December, 2012) The only available remedy for IRS actions that are favorable to taxpayers is through the political process. The IRS and the Treasury Department typically do not interpret tax statutes in a taxpayer-friendly manner. However, on occasion they do just that, and thus a tax practitioner may be faced with taking a tax return position or suggesting a tax... 2012
Theodore Eisenberg THE CBP RACE STUDY: A PATHBREAKING CIVIL JUSTICE STUDY AND ITS SENSITIVITY TO DEBTOR INCOME, PRIOR BANKRUPTCY, AND FORECLOSURE 20 American Bankruptcy Institute Law Review 683 (Winter 2012) Choice of bankruptcy chapter provides an unusual opportunity to assess race effects on a civil law outcome in a reasonably well controlled context. Although the merits of legal cases are difficult to control for, sometimes the merits can be held constant. In medical malpractice cases, ex-post reviews of medical records can provide reasonable... 2012
Lois R. Lupica THE CONSUMER BANKRUPTCY FEE STUDY: FINAL REPORT 20 American Bankruptcy Institute Law Review 17 (Spring, 2012) C1-2Table of Contents List of Figures 20 List of Tables 21 List of Maps 23 List of Regression Models 24 Foreword 25 Introduction 27 Summary of Findings 30 I. The Consumer Bankruptcy System 32 II. The Bankruptcy Code and Rule Provisions Governing Attorney Compensation 37 III. Studies of the Consumer Bankruptcy System and Profiles of Consumer Debtors... 2012
Jonathan P. Schneller THE EARNED INCOME TAX CREDIT AND THE ADMINISTRATION OF TAX EXPENDITURES 90 North Carolina Law Review 719 (March, 2012) The field of tax expenditure analysis has generally assumed a binary choice between tax expenditures and direct outlays. Because tax expenditures have multiple traits that are said to render them a suboptimal spending mechanism, scholars have tended to argue that they should be eliminated outright, or that they should be recast as direct... 2012
Reuven S. Avi-Yonah , Yaron Lahav THE EFFECTIVE TAX RATES OF THE LARGEST U.S. AND EU MULTINATIONALS 65 Tax Law Review 375 (Spring 2012) The United States has the second highest statutory corporate tax rate in the Organization for Economic Co-Operation and Development (OECD) (after Japan). This has not always been the case. After the Tax Reform Act of 1986 lowered the U.S. rate from 46% to 34%, the United States had one of the lowest statutory corporate tax rates in the OECD. In the... 2012
Karen B. Brown, Mary Louise, Bridget J. Crawford THE PAST, PRESENT, AND FUTURE OF CRITICAL TAX THEORY: A CONVERSATION 10 Pittsburgh Tax Review 59 (Fall, 2012) The publication of Taxing America in 1997 is a key milestone in the development of critical tax theory as an intellectual discipline. By identifying and bringing together lawyers and scholars with an interest in the political and discriminatory aspects of tax law, Professor Karen B. Brown and Professor Mary Louise Fellows created one of the... 2012
Ashley W. Edwards THERE'S NO BUSINESS LIKE THE STATE FILM TAX INCENTIVE BUSINESS: AN ANALYSIS OF PENNSYLVANIA'S FILM PRODUCTION TAX CREDIT PROGRAM 13 University of Pittsburgh Journal of Technology Law and Policy 1 (Fall, 2012) Bat mobiles racing down Grant Street, fans filling Heinz Stadium bundled in black and yellow in the middle of the summer, and celebrity sightings in local restaurants can cause excitement in the Pittsburgh metropolis. The Steel City is just one of many areas in Pennsylvania that has seen a surge of film production in recent years, causing buzz that... 2012
Susan Ardisson THIRD CIRCUIT PROVIDES "DEFINITIVE GUIDANCE" ON TAXATION OF ESI COSTS 14 Lawyers Journal 6 (June 1, 2012) In a much anticipated decision, the Third Circuit in Race Tires America, Inc. v. Hoosier Racing Tire Corp., _ F.3d _ (3d Cir. (Pa.) March 16, 2012 (No. 11-2316), held that most expenses associated with the collection, processing and production of electronically stored information (ESI) were not taxable as costs under 28 U.S.C. S1920(4) because they... 2012
Ruth Mason, Michael S. Knoll WHAT IS TAX DISCRIMINATION? 121 Yale Law Journal 1014 (March, 2012) Prohibitions of tax discrimination have long appeared in constitutions, tax treaties, trade treaties, and other sources, but despite their ubiquity, little agreement exists as to how such provisions should be interpreted. Some commentators have concluded that tax discrimination is an incoherent concept. In this Article, we argue that in common... 2012
Steven L. Schwarcz A MINIMALIST APPROACH TO STATE "BANKRUPTCY" 59 UCLA Law Review 322 (December, 2011) Increasingly finding themselves in fiscal straightjackets, states have been turning to austerity measures, tax increases, privatization of services, and renegotiation of collective bargaining agreements. Absent a federal government bailout, however, states will also need debt relief if their debt burden becomes so crushing that reasonable efforts... 2011
Amanda M. Murphy A TALE OF THREE SOVEREIGNS: THE NEBULOUS BOUNDARIES OF THE FEDERAL GOVERNMENT, NEW YORK STATE, AND THE SENECA NATION OF INDIANS CONCERNING STATE TAXATION OF INDIAN RESERVATION CIGARETTE SALES TO NON-INDIANS 79 Fordham Law Review 2301 (April, 2011) This Note examines the conflict between New York State and the Seneca Nation of Indians regarding the taxation of cigarette sales to non-Indians on Indian reservations. In 1994, the United States Supreme Court found New York's taxation scheme facially permissible without providing boundaries or guidance for the state's subsequent enforcement.... 2011
Adam Chodorow CHARITABLE FSAS: A PROPOSAL TO COMBINE HEALTHCARE AND CHARITABLE GIVING TAX PROVISIONS 2011 Brigham Young University Law Review 1041 (2011) This Article considers two unrelated tax provisions--health care Flexible Spending Accounts (FSAs) and the charitable deduction. FSAs permit eligible taxpayers to set income aside tax-free to use for medical expenses. However, these accounts have a use-it-or-lose-it feature that discourages participation and creates incentives for unnecessary... 2011
Kenneth C. Kettering CODIFYING A CHOICE OF LAW RULE FOR FRAUDULENT TRANSFER: A MEMORANDUM TO THE UNIFORM LAW COMMISSION 19 American Bankruptcy Institute Law Review 319 (Winter 2011) C1-3TABLE OF CONTENTS I. The Proposal. 320 II. Background. 320 III. Illustrative Circumstances in Which it May Be Important Which Jurisdiction's Fraudulent Transfer Law Applies. 324 A. Significance of Choice of Law as Between States that Have Enacted the UFTA. 325 1. Different Substantive Law in UFTA States as a Result of Differing Application of... 2011
George Lefcoe COMPETING FOR THE NEXT HUNDRED MILLION AMERICANS: THE USES AND ABUSES OF TAX INCREMENT FINANCING 43 Urban Lawyer 427 (Spring, 2011) Demographers predict that the u.s. population will grow by one hundred million by 2050. Newcomers are expected to continue the trend to suburbia-- particularly to the fast-growing big cities of the south and west; cities in the resurgent heartland of the country; exurbia; and a string of discernible superstar cities, mostly coastal. Many... 2011
Marla Schwaller Carew DISCRETION AND DETERRENCE IN TAX SENTENCING AFTER RITA, GALL AND KIMBROUGH - OPPORTUNITIES FOR ALTERNATIVE SENTENCES AND POTENTIAL ABUSES 9 Florida Tax Review 919 (2011) I. Introduction. 921 II. The Foundations of Rita, Gall and Kimbrough and the History of Tax Sentencing. 924 A. Prehistory and Creation of the Federal Sentencing Guideline. 924 B. Sociological Roots of White Collar Crime and the Guidelines's Focus on Offense, Rather Than Offender. 928 C. Seeds of Uncertainty: Koon, Apprendi/Blakely and Booker. 930... 2011
Miranda Perry Fleischer EQUALITY OF OPPORTUNITY AND THE CHARITABLE TAX SUBSIDIES 91 Boston University Law Review 601 (March, 2011) Introduction. 603 I. The Charitable Tax Subsidies and Their Theoretical Foundations. 606 A. Why Subsidize Charity?. 609 B. Why Use the Tax System to Subsidize Charity? Efficiency, Pluralism, and the Donative Theory. 612 C. Unanswered Questions. 614 1. Current Law Is Vague and Inconsistent. 615 2. Existing Scholarship Is Incomplete and Inconsistent.... 2011
Ruth Mason FEDERALISM AND THE TAXING POWER 99 California Law Review 975 (August, 2011) Scholars and courts recognize that the federal government uses its broad spending power to enlist states in achieving federal goals, thereby expanding the federal government's reach beyond the areas enumerated for it in the Constitution. Previously underappreciated, however, is that the federal government can achieve similar ends--it can regulate... 2011
Maximilian Held GO FORTH AND SIN [TAX] NO MORE: IMPORTANT TAX PROVISIONS, AND THEIR HAZARDS, IN THE PATIENT PROTECTION AND AFFORDABLE CARE ACT 46 Gonzaga Law Review 717 (2010-2011) I. Introduction. 717 II. Background. 719 A. The Patient Protection and Affordable Care Act. 719 B. Significant Non-tax Provisions of the PPACA. 720 C. The Taxation Power, Generally. 721 III. Controversial Tax Policies Within the PPACA. 723 A. The Individual and Employer Mandates. 723 1. Summary of the Individual Mandate. 723 2. Summary of the... 2011
Anthony C. Infanti INEQUITABLE ADMINISTRATION: DOCUMENTING FAMILY FOR TAX PURPOSES 22 Columbia Journal of Gender and Law 329 (2011) Family can bring us joy, and it can bring us grief. It can also bring us tax benefits and tax detriments. Often, as a means of ensuring compliance with Internal Revenue Code provisions that turn on a family relationship, taxpayers are required to document their relationship with a family member. Most visibly, taxpayers are denied an additional... 2011
David Spencer INTERNATIONAL TAX COOPERATION: CENTRIFUGAL VS. CENTRIPETAL FORCES-A FOLLOW-UP 22 Journal of International Taxation 35 (November, 2011) This article picks up the analysis with recent developments that have propelled the process toward more intensive international tax cooperation, and the capacity of major emerging economies to devise coordinated and cohesive policies and actions to intensify international tax cooperation to their advantage. A previous article by this author in the... 2011
Jeremy Leong IS CHAPTER 15 UNIVERSALIST OR TERRITORIALIST? EMPIRICAL EVIDENCE FROM UNITED STATES BANKRUPTCY COURT CASES 29 Wisconsin International Law Journal 110 (Spring 2011) This article reports the findings of an empirical study of relief granted in all Chapter 15 cases filed since the U.S. Congress enacted it in 2005. It argues that U.S. courts applying Chapter 15 have not unconditionally turned over debtor's assets in the United States to foreign main proceedings. The results of the study show that while U.S. courts... 2011
Hugo A. Hurtado IS LATIN AMERICAN TAXATION POLICY APPROPRIATE FOR PROMOTING FOREIGN DIRECT INVESTMENT IN THE REGION? 31 Northwestern Journal of International Law and Business 313 (Spring 2011) The purpose of this article is to analyze whether the international tax policy adopted by different Latin American countries is the most appropriate for promoting foreign direct investment and what measures can be adopted by these countries in order to improve such policy. One of the most relevant indicators of the quality of life for citizens of a... 2011
Amanda Berman ISN'T IT IRONIC? THE UNDERMINING OF AMERICAN PUBLIC POLICY BY AMERICAN TAX LAW, AND THE RAMIFICATIONS ON MIDDLE EAST PEACE 10 Cardozo Public Law, Policy and Ethics Journal 81 (Fall 2011) Introduction. 82 I. Historical Transformation to Modern Law of Charitable Organizations. 86 A. Underlying Purposes of Tax Exemption and Tax Deduction. 88 B. Determining When an Organization May Qualify Under § 501(c)(3) or § 501(c)(4) of the Internal Revenue Code. 90 II. Designation as a Charitable Organization Under the Modern Internal Revenue... 2011
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