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Ineffective and Inequitable: The Section 265(a) Interest DisallowanceRonald BlasiGeorgia State University College of Law C. James Judsonaffiliation not provided to SSRN 1990 Wake Forest Law Review, Vol. 25, p. 811, 1990 Abstract: This article argues for the repeal of Code section 265(a) because it is ineffective, creates horizontal inequities, and represents overwhelming administrative enforcement difficulties. Consistent with the repeal of the section should be a repeal of Code section 103. The market for municipal banks will operate more efficiently without these Code sections.
Number of Pages in PDF File: 20 Keywords: tax, taxation, tax law, Internal Revenue Code, Section 265(a), Section 103, banking JEL Classification: K22, K34 Accepted Paper SeriesDate posted: October 13, 2009Suggested CitationContact Information
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