CONTENTS I. MAJOR OBJECTIVES AND GUIDES FOR TAX REFORM A. GENERAL APPRAISAL OF THE INCOME TAX The Federal Income Tax Base for Individuals-Stanley S. Surrey. Major Objectives of and Guides for Income Tax Reform-Joseph Sneed__ Federal Income Tax Revision-Roswell Magill. Objectives of and Guides for Tax Rate Reform-John C. Davidson.. Page 1 19 61 77 87 107 119 139 157 B. THE RELATIVE ROLE OF INCOME TAXES IN THE TAX SYSTEM The Role of Income Taxes in the U.S. Tax System and the Scope of Tax The Role of Individual Income Taxes in Federal-State-Local Fiscal Relationships-Robert R. Nathan and Edward D. Hollander.. The Corporation Income Tax: An Empirical Appraisal-Arnold C. A. INDIVIDUAL INCOME TAX EXCLUSIONS Consistent Treatment of Items Excluded and Omitted From the Individual Income Tax Base-Melvin I. White_. An Appraisal of Individual Income Tax Exclusions-Roy Wentz 317 329 341 351 Social Security and the Personal Income Tax-Raymond Muntz - 353 B. INDIVIDUAL INCOME TAX DEDUCTIONS Pag Personal Deductions in the Individual Income Tax-C. Harry Kahn......... Deductions and Credits for State Income Taxes-Walter W. Heller.. The Individual Income Tax Base and the Charitable Contributions De- Individual Income Tax Deductions Applying to Gifts to Colleges and C. TAXATION OF FAMILY INCOME Income Splitting-Joseph A. Pechman.. 39 407 419 435 441 447 457 473 An Inquiry into the Possibility of Lowering the Tax Rates by Increasing 487 The Place of the Personal Exemptions in the Present-Day Income Tax- 493 To Restore Balance and Equity in Family Income Taxation-Everett M. 515 Personal Exemptions-Martin Atlas. 525 Parent and Child-and Taxes: Some Problems in Dependency-C. Lowell 531 Treatment of Family Income-Paul Strayer 537 D. TAXATION OF THE AGED Income and Tax Status of the Aged: Present Situation and Possible Taxation of the Aged: Retirement Income Credit and the Like-Eveline Taxation of the Aged-Dwight S. Sargent. Taxation of the Aged-Ethel Percy Andrus_. E. TAXATION OF FLUCTUATING INCOMES Effect of Taxation on Individuals with Fluctuating Incomes-Adrian 539 551 559 563 579 Averaging Income for Income Tax Purposes-Wilbur A. Steger. Federal Tax Treatment of Fluctuating Income-William A. Cromartie... An Averaging Proposal-Ralph Becker. F. THE EXEMPTION OF INTEREST ON STATE AND LOCAL BONDS 679 Exclusion From Income of Interest on State and Local Government Obli- 701 Interest on State and Local Bonds and the Federal Income Tax-Harvey 721 Exclusion From Taxable Income of Interest on Municipal Bonds To Sub- 729 737 775 Federal Taxation of the Interest Paid by States and Political Subdivisions VOLUME 2 783 G. BUSINESS DEDUCTIONS 1. Depreciation Effects of Depreciation Allowances for Tax Purposes-Robert Eisner. 793 801 Page Accelerated Depreciation-Sidney Davidson. Depreciation Policy for an Expanding Economy-George Kitendaugh___ The Depreciation Deduction-LIFO Principle Should Be Extended To 807 813 827 841 857 The Deduction for Percentage Depletion and Exploration and Develop- 933 Percentage Depletion and Resource Allocation-Peter O. Steiner.. Tax Reform and the Depletion Allowance-Horace M. Gray. Depletion and Exploration and Development Costs of the Mining In- Percentage Depletion and Exploration and Development Costs-Rolla D. 1041 3. General Business Expenses Business Expense Deductions: Travel and Entertainment-V. Henry 1061 General Business Expenses Other than Depreciation. Depletion and Explor- 1069 Business Deductions and General Business Expenses-Edward J. Schlaudt 1073 1075 1085 1097 4. Research and Development Expenditures Income Tax Provisions Regarding Research and Development Expendi- 1105 Research and Development Costs-Charles R. Orem, Jr. 1111 1115 H. ACCOUNTING PROVISIONS Accounting Provisions-John M. Sullivan__ 1125 Tax Accounting for Prepaid Income and Reserves for Future Expenses- 1133 An Evaluation of the Accounting Provisions of the Internal Revenue Code 1161 An Analysis of Accounting Provisions-Willard J. Graham_. 1175 1183 I. TREATMENT OF CAPITAL GAINS Taxation of Capital Gains-Harold M. Groves.. 1193 Definitional Problems in Capital Gains-Stanley S. Surrey.. 1203 Tax Treatment of Capital Gains-Dan Throop Smith... 1233 The Paradox of Capital Gains: Taxable Income that Ought Not To Be 1243 Page Taxation of Capital Gains-Merle H. Miller 1257 Economic Consequences of Substantial Changes in the Method of Taxing Capital Gains and Losses-Wilbur A. Steger... 1261 The Capital Asset Definition-Leonard Silverstein.. 1285 J. PENSIONS AND OTHER EMPLOYEE BENEFIT PLANS Some Characteristics of Private Pension Plans-Daniel M. Holland... 1301 1327 1337 1347 Pension and Other Employee Benefit Plans-Joseph L. Seligman, Jr.. 1353 1375 Pension and Other Employee Benefit Plans-Leonard Lesser 1383 1391 K. COMPLIANCE AND ENFORCEMENT 1. Amount of Unreported Income Unreporting of Dividends and Interest on Tax Returns-Daniel M. Hol- 1397 Coverage of Entrepreneurial Income on Federal Tax Returns-C. Harry 1439 2. Procedures to Improve Income Reporting Improving Income Tax Reporting-Russell C. Harrington. 1461 1467 1479 1499 Revision of Tax Administration Standards for Better Reporting of Taxable 1507 The Underreporting of Farm Income: Problems and Recommendations- 1519 Compliance and Enforcement: Procedures for Reducing Underreporting- 1527 1531 The Fable of the Seven Heavens-Michael D. Bachrach_ VOLUME 3 IV. THE TAXABLE ENTITY A. TREATMENT OF DIVIDENDS Taxation of Dividends-Carl S. Shoup-- Tax Treatment of Dividends-Dan Throop Smith.. Stockholder Differential Taxation and Tax Relief-Daniel M. Holland. Income Taxation and Dividend Income-Paul G. Darling- D. TREATMENT OF PARTNERSHIPS AND CORPORATIONS TREATED Page Treatment of Partners and Partnerships-Arthur Willis_ Subchapter S-Election of Small Business Corporations-Mortimer M. Subchapter S-Its Role in the Tax Laws-Joseph P. Driscoll.. E. INCOME OF ESTATES AND TRUSTS Estates and Trusts-Norman A. Sugarman Income of Estates and Trusts-James P. Johnson and Weston Vernon, Jr.. V. SPECIAL PROBLEMS IN CORPORATE Taxation A. MUTUAL FINANCIAL COMPANIES B. COOPERATIVES The Exemption of Cooperatives from Income Taxation-Roswell Magill. Tax Treatment of Insurance Companies-Roy E. Moor.. The Tax Treatment of Life Insurance George E. Lent. Federal Taxation of Insurance Companies-S. Alexander Bell Taxation of Mutual Life Insurance Companies-H. Ladd Plumley- |