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When Is A Dividend Taxed?
August 28, 2014
In April, 1963, the taxpayer, (M), entered into an agreement for the purchase of the stock of four corporations, SE1, SU, SE2, and SE3. The total sale price was $500,...

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Recent Reports

Most Assets Are "Capital" Assets
August 27, 2014
In a case entitled Arkansas Best Corp. v. Commissioner , 485 US 212 (1988), decided by the Supreme Court, the issue was whether corporate stock held by Arkans...
BKW and THI Will Effect A "Non-Abusive" Inversion Transaction
August 26, 2014
Not surprisingly, given the advance publicity, Burger King Worldwide, Inc. (BKW), and Tim Hortons, Inc., (THI), announced today their intention to join forces in a transaction...
TRS Can Own Lodging Facility
August 26, 2014
TP is a Real Estate Investment Trust, (REIT). TP owns substantially all of its assets and conducts substantially all of its operations through a Partnership, (PS), in...
"Admission Fees" Subject To Amusement Tax
August 25, 2014
All home games played by the Chicago Bears were played at Soldier Field during the periods at issue. Soldier Field has approximately 62,000 seats divided into three sections: r...