Stock redemption costs: an analysis of conflicting judicial interpretations
Article Abstract:
Two inconsistent positions have developed due to judicial uncertainty regarding the deductibility of stock redemption expenses incurred during leveraged buyouts. IRC section 162(k) was enacted to limit deductions for greenmail expenses, but the Tax Court in Fort Howard Corp. v. Commissioner interpreted the statute to apply to all stock redemption expenses based on the primary purpose test. The US Court of Appeals reach an opposite conclusion in United States v. Kroy in finding that that origin of claim test was applicable.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
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IRS hopes to get employee tip reporting on "TRAC." (Tip Reporting Alternative Commitment)
Article Abstract:
IRS's Tip Reporting Alternative Commitment (TRAC) requires employers to educate employees on tip-reporting while limiting employers' tax liabilities. A TRAC agreement contains provisions covering reporting, recordkeeping, tax deposits, applications and revocation procedures. Under a TRAC agreement, restaurants' liabilities for social security and Medicare taxes are limited to employees' reported tips or tips discovered in audits.
Publication Name: Taxes: The Tax Magazine
Subject: Business
ISSN: 0040-0181
Year: 1995
User Contributions:
Comment about this article or add new information about this topic:
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