This is a comprehensive casebook on federal income taxation of corporations, focusing almost entirely on issues arising under Subchapter C of the Internal Revenue Code. It is aimed at students who have already completed a basic course in federal income taxation, and so have an understanding of basic tax concepts. In addition to helping students understand the statutes and their administrative and judicial overlays, the book encourages them to evaluate the law and the various proposals for changing it. Attention is given to identifying long term trends and challenges.


Imprint: Foundation Press
Series: University Casebook Series
Publication Date: 11/29/2012

Bernard Wolfman, Harvard University Law School

Diane M. Ring, Boston College Law School

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Changes in the new edition include: a. Examination of the impact of the long lasting reduction in the tax rate for dividends; b. Impact of the new statutory economic substance doctrine under section 7701(o); c. New regulations, including continuity of interest; d. Providing (in the notes) updated resources for additional reading and research opportunities on the major topics throughout the casebook; e. Deletion of rulings that are not sufficiently relevant today; f. Updated revenue procedures; g. Addition of new cases in the notes to identify continued application of various rules, principles and concepts by the courts, including Altria Group Inc. v. U.S. 658 F.3d 276 (2011); Pritired, LLC v. U.S., 816 F.Supp. 2d 693 (2011); TIFDIII-E, Inc. v. U.S., 666 F3rd 836 (2nd Cir. 2012); U.S. v. Ohle, 441 Fed. Appx 798 (2dCir. 2011); Knutsen-Rowell. Inc. v. Comm., T.C. Memo 2011-65.

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