Calvin H. Johnson

University of Texas at Austin - School of Law

John T. Kipp Chair in Corporate and Business Law

727 East Dean Keeton Street

Austin, TX 78705

United States

SCHOLARLY PAPERS

125

DOWNLOADS

14,745

SSRN CITATIONS

31

CROSSREF CITATIONS

34

Scholarly Papers (125)

1.

Why Stock and Stock-Option Compensation are Such a Terrible Idea

Number of pages: 26 Posted: 19 Dec 2003
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 956 (42,342)
Citation 1

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2.

Brief of Amici Curiae Tax Law Professors and Economists in Support of Petitioner in South Dakota v. Wayfair

Number of pages: 30 Posted: 06 Nov 2017
New York University School of Law, University of Michigan Law School, Stanford Law School, University of Southern California Gould School of Law, New York University School of Law, Fordham University School of Law, Loyola University Chicago School of Law, Brigham Young University - J. Reuben Clark Law School, Indiana University Maurer School of Law, Northwestern Pritzker School of Law, Stanford Law School, Elon University School of Law, Valparaiso University Law SchoolErnst & Young, University of Richmond - School of Law, University of Texas at Austin - School of Law, University of Illinois College of Law, University of Pennsylvania Carey Law School, Yale University - Law School, Yale Law School, University of Virginia School of Law, Kelley School of Business, Southern Methodist University - Dedman School of Law, University of Texas at Austin - School of Law, University of Connecticut - School of Law, Boston College - Law School, University of Chicago Law School, University of Richmond School of Law, Arizona State University (ASU) - Sandra Day O'Connor College of Law, New York University School of Law, Rutgers University, University of Colorado Law School, University of California, Los Angeles (UCLA) - School of Law, University of Arizona - James E. Rogers College of Law, University of Nebraska College of Law, UC Law, San Francisco, Yeshiva University - Benjamin N. Cardozo School of Law and University of California, Los Angeles (UCLA) - School of Law
Downloads 446 (112,559)
Citation 1

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amicus brief, Supreme Court, stare decisis, dormant Commerce Clause, Quill v. North Dakota, South Dakota v. Wayfair

3.

The Tax Explanation for the Romney Leveraged Buyouts

Tax Notes, p. 579, July 2012, U of Texas Law, Law and Econ Research Paper No. 230, U of Texas Law, Public Law Research Paper No. 237
Number of pages: 10 Posted: 07 Aug 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 424 (119,769)

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4.

Accurate and Honest Tax Accounting for Oil and Gas

Tax Notes, Vol. 125, No. 5, pp. 573-583, 2009, The Shelf Project
Number of pages: 12 Posted: 10 Nov 2009 Last Revised: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 404 (126,682)
Citation 1

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Shelf Project, tax reform, tax accounting, oil and gas

Stock Compensation: The Most Expensive Way to Pay Future Cash

Number of pages: 53 Posted: 25 Jun 1999
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 397 (128,125)
Citation 1

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Stock Compensation: The Most Expensive Way to Pay Future Cash

Southern Methodist University Law Review, Vol. 52, July 1999
Posted: 25 Jun 1999
Calvin H. Johnson
University of Texas at Austin - School of Law

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6.

Were Trump's Fake Losses Legal as Tax Deductions?

U of Texas Law, Public Law Research Paper
Number of pages: 7 Posted: 23 Oct 2016 Last Revised: 29 Oct 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 300 (175,148)

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7.

Amended Returns - Imposing a Duty to Correct Material Mistakes

The Shelf Project, Tax Notes, Vol. 120, p. 979, September 8, 2008
Number of pages: 7 Posted: 09 Dec 2009
Calvin H. Johnson and Keith Fogg
University of Texas at Austin - School of Law and Tax Clinic at Legal Services Center of Harvard Law School
Downloads 289 (182,170)

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8.

Tales from the Kpmg Skunk Works: The Basis-Shift or Defective-Redemption Shelter

Tax Notes, p. 431, July 25, 2005, U of Texas Law and Economics Research Paper No. 051
Number of pages: 14 Posted: 31 Aug 2005
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 288 (182,835)

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tax shelters, basis, dividends, substance-over-form

9.

Apportionment of Direct Taxes: The Glitch in the Center of the Constitution

Number of pages: 110 Posted: 11 Nov 1997
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 283 (186,095)
Citation 2

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10.

Profits from Tax Evasion Under the Midco Transaction

Tax Notes, p. 45, March 2013, U of Texas Law, Public Law Research Paper No. 444, The Shelf Project
Number of pages: 10 Posted: 23 Apr 2013
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 255 (206,751)

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11.

Why Do Venture Capital Funds Burn Research and Development Deductions?

U of Texas Law, Law and Econ Research Paper No. 118
Number of pages: 64 Posted: 04 Dec 2007 Last Revised: 04 Jun 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 235 (223,917)
Citation 4

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tax, venture capital, R&D

12.

Choice of Entity by Reason of Tax Rates

Tax Notes, Vol. 158, No. 12, 2018, U of Texas Law, Public Law Research Paper
Number of pages: 7 Posted: 07 May 2018
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 228 (230,562)

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13.

The Effective Tax Ratio and the Undertaxation of Intangible Investments

U of Texas Law, Law and Econ Research Paper No. 135
Number of pages: 36 Posted: 14 Sep 2008 Last Revised: 27 Aug 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 227 (231,494)
Citation 2

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Effective tax rate, intangibles, corporate income tax, effective tax ratio

14.

Don’t Let Capital Accounts go Negative

Tax Notes, 2010, U of Texas Law, Law and Econ Research Paper No. 191, The Shelf Project
Number of pages: 13 Posted: 16 Nov 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 213 (245,832)

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15.

Capitalize Costs of Software Development

Tax Notes, Vol. 124, No. 6, pp. 603-612, August 10, 2009, The Shelf Project
Number of pages: 11 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 183 (281,978)

Abstract:

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software, capitalization

16.

A Wealth Tax is Constitutional

ABA Tax Times, August 2019 • Vol. 38 No. 4
Number of pages: 10 Posted: 21 Aug 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 182 (283,353)

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Wealth Tax, Constitutionality

17.

How to Raise $1 Trillion Without a VAT or a Rate Hike

Tax Notes, Vol. 128, p. 101, July 5, 2010
Number of pages: 8 Posted: 10 Jul 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 177 (290,329)

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Tax Reform, Revenue Enhancement, Tax Accounting

Extend the Tax Life For Acquired Intangibles To 75 Years

Tax Analysis, 135 Tax Notes 1054 (May 21, 2012), , U of Texas Law, Public Law Research Paper No. 559
Number of pages: 16 Posted: 27 Apr 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 89 (492,891)
Citation 1

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Extend the Tax Life for Acquired Intangibles to 75 Years

Tax Notes, Vol. 135, p. 1054, May 2012, The Shelf Project, U of Texas Law, Public Law Research Paper No. 221
Number of pages: 15 Posted: 31 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 85 (507,596)

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19.

‘Contributions to Capital’ from Nonowners

126 Tax Notes, p. 1127, 2010
Number of pages: 10 Posted: 04 Mar 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 161 (315,018)

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contributions to capital, tax reform

20.

Replace the Corporate Tax with a Market Capitalization Tax

Tax Notes, Vol. 117, pp.1082, December 10, 2007, The Shelf Project
Number of pages: 7 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 160 (316,697)

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corporate tax, market capitaliztion tax, tax

21.

Sale of Goodwill and Other Intangibles as Ordinary Income

Tax Notes, Vol. 118, p. 321, January 2008, The Shelf Project
Number of pages: 6 Posted: 08 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 157 (321,806)

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goodwill, intangibles, income, tax reform

22.

The Shelf Project: 82 Fair and Efficient Suggestions to Raise $3.5 Trillion

173 Tax Notes Federal 39 (Oct 4, 2021)
Number of pages: 30 Posted: 28 Sep 2021
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 156 (323,522)

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Income tax, tax base, tax reform

23.

Recognizing Built-In Gain on Contribution to a Partnership

Tax Notes, pp. 905-919, November 2011, U of Texas Law, Public Law Research Paper No. 204, U of Texas Law, Law and Econ Research Paper No. 218, The Shelf Project
Number of pages: 16 Posted: 17 Nov 2011
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 154 (325,267)
Citation 1

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24.

A Conceptual Framework for Capital Gain

Florida Tax Review, Vol. 20, No. 10, 2017, U of Texas Law, Public Law Research Paper
Number of pages: 76 Posted: 04 Oct 2017 Last Revised: 24 Oct 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 150 (332,448)

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25.

The Tax Cut Bill Would Push U.S. Debt Over the Critical Breaking Point

U of Texas Law, Public Law Research Paper No. 689
Number of pages: 5 Posted: 20 Nov 2017 Last Revised: 06 Dec 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 145 (341,639)

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26.

We Don't Need No Stinkin' VAT

Tax Notes, p. 527, April 2013, U of Texas Law, Public Law Research Paper No. 448
Number of pages: 6 Posted: 22 May 2013
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 143 (345,435)

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27.

When ‘Simplification’ is a Trojan Horse for Great Harm

Tax Notes, Vol. 146, No. 9, 2015, U of Texas Law, Public Law Research Paper No. UTPUB627
Number of pages: 8 Posted: 27 May 2015
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 141 (349,289)

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28.

Small Business Inventory Expensing

Tax Notes, 2010, U of Texas Law, Law and Econ Research Paper No. 193, The Shelf Project
Number of pages: 11 Posted: 16 Nov 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 140 (351,261)

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Repeal Tax Exemption for Municipal Bonds

Tax Notes, Vol. 117, p. 1259, December 2007, The Shelf Project
Number of pages: 6 Posted: 08 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 82 (515,170)

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tax exemption, municipal bonds

Repeal Tax Exemption for Municipal Bonds

Tax Notes, Vol. 117, p. 1259, 2007, The Shelf Project
Number of pages: 5 Posted: 30 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 52 (659,117)

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30.

Repeal Opportunity Zones

Tax Notes, Vol. 169,, pp. 625-630, October 26, 2020 The Shelf Project, U of Texas Law, Law and Econ Research Paper
Number of pages: 6 Posted: 11 Nov 2020
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 133 (365,374)

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taxation, Opportunity Zones

31.

Partnership Allocations from Nickel-on-The-Dollar Substance

Tax Notes, Vol. 134, p. 873, February 2012, U of Texas Law, Public Law Research Paper No. 205, U of Texas Law, Law and Econ Research Paper No. 220
Number of pages: 14 Posted: 17 Feb 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 130 (371,755)

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32.

Tax on Insurance Buildup

Tax Notes, Vol. 122, p. 665, February 2, 2009, The Shelf Project
Number of pages: 8 Posted: 09 Dec 2009
Calvin H. Johnson, Andy Pike and Eric A. Lustig
University of Texas at Austin - School of Law, American University - Washington College of Law and New England Law | Boston
Downloads 130 (371,755)

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tax reform,life insurance

33.

Common Trust Funds: The Living Fossil of Passthroughs

Tax Notes, Vol. 127, p. 103, April 5, 2010, U of Texas Law, Law and Econ Research Paper No. 182, The Shelf Project
Number of pages: 11 Posted: 08 Apr 2010 Last Revised: 23 Aug 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 126 (380,654)

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tax reform, common trust fund

34.

'Perpetual Trusts: The Walking Dead' and 'Congress Should Effectively Curb GST Exemption for Perpetual Trusts'

Tax Notes, Vol. 136, No. 10, 2012, U of Michigan Law & Econ Research Paper No. 12-019, U of Michigan Public Law Research Paper No. 290
Number of pages: 4 Posted: 18 Sep 2012 Last Revised: 24 Sep 2012
Lawrence W. Waggoner and Calvin H. Johnson
University of Michigan Law School and University of Texas at Austin - School of Law
Downloads 125 (383,016)
Citation 1

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Trusts, GST Exemption, Perpetual Trusts

35.

Measure Tax Expenditures by Internal Rate of Return

Tax Notes, SPECIAL REPORT, April 15, 2013
Number of pages: 17 Posted: 18 Apr 2013
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 122 (390,035)

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36.

'Impost Begat Convention': Albany and New York Confront the Ratification of the Constitution

80 Alb. L. Rev. 1489 (2016/2017), U of Texas Law, Public Law Research Paper
Number of pages: 34 Posted: 14 Dec 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 121 (392,446)

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37.

States' Rights[?]

U of Texas Law, Public Law Research Paper No. 130
Number of pages: 50 Posted: 14 Oct 2007
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 119 (397,237)

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states' rights, constitution, direct tax

38.

Bought Law

Number of pages: 3 Posted: 07 Nov 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 116 (404,638)

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39.

Passing Estate Tax Values Through the Eye of a Needle

Tax Notes, Vol. 132, No. 9, 2011, FSU College of Law, Public Law Research Paper No. 531
Number of pages: 9 Posted: 02 Sep 2011
Calvin H. Johnson and Joseph M. Dodge
University of Texas at Austin - School of Law and Florida State University - College of Law
Downloads 115 (407,226)

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40.

A Thermometer for the Tax System: The Overall Health of the Tax System as Measured by Implicit Tax

U of Texas Law and Economics Research Paper No. 015
Number of pages: 41 Posted: 29 Apr 2004
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 115 (407,226)

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41.

No Orchard, No Capital Gain

71 Tax Lawyer 501 (2019) , U of Texas Law, Public Law Number 702
Number of pages: 19 Posted: 29 Jun 2019 Last Revised: 26 Sep 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 114 (409,833)

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Capital gain taxation

42.

Ending Reliance on Opinions of the Taxpayer's Own Lawyer

Tax Notes, Vol. 141, No. 947, 2013, U of Texas Law, Public Law Research Paper No. 546
Number of pages: 17 Posted: 11 Dec 2013 Last Revised: 13 Feb 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 114 (409,833)

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43.

Organizational Capital: The Most Important Unsettling Issue in Tax

Tax Notes, Vol. 148, No. 6, 2015
Number of pages: 12 Posted: 26 Aug 2015
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 113 (412,441)

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First Do No Harm: The Senate Staff Discussion Draft on Cost Recovery

Tax Notes, Vol. 142, No. 549, 2014, U of Texas Law, Public Law Research Paper No. 550
Number of pages: 8 Posted: 14 Feb 2014 Last Revised: 21 Mar 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 86 (500,117)

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First Do No Harm: The Senate Staff Discussion Draft on Cost Recovery

Tax Notes, Vol. 142, p. 549, February 2014, The Shelf Project, Forthcoming
Number of pages: 7 Posted: 14 Feb 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 26 (851,683)

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45.

Fixing the Double Deduction from Carried Interest

The Shelf Project Tax Notes, p. 203, April 2011
Number of pages: 12 Posted: 26 Apr 2011
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 110 (420,590)
Citation 1

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46.

Winter is Coming: Tax Policy for the Coming Bitter Hard Times: A Review of Robert J. Gordon, The Rise and Fall of American Growth

157 Tax Notes 851 (Nov. 6, 2017) , U of Texas Law, Public Law Research Paper No. 580
Number of pages: 11 Posted: 07 Dec 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 109 (423,336)
Citation 1

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47.

Corporate Meltdowns and the Deduction of Credit Risk Interest

Tax Notes, Vol. 131, p. 513, May 2011, The Shelf Project
Number of pages: 5 Posted: 31 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 109 (423,336)

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48.

Gains and Losses on Business Depreciable Property

Tax Notes, Vol. 126, p. 787, February 2010
Number of pages: 7 Posted: 23 Feb 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 109 (423,336)

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Tax Reform, Capital Gains, Business Deduction

49.

The Dubious Enumberated Power Doctrine

U of Texas Law, Public Law Research Paper No. 107, Constitutional Commentary, Vol. 22, 2005
Number of pages: 68 Posted: 21 Sep 2006
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 109 (423,336)
Citation 1

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50.

UBIT to the Defense! ESOPs and Government Entities

Tax Notes, Vol. 128, p. 317, July 18, 2010
Number of pages: 5 Posted: 12 Aug 2010
Calvin H. Johnson and Ellen P. Aprill
University of Texas at Austin - School of Law and Loyola Law School Los Angeles
Downloads 108 (426,229)

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unrelated business income tax, UBIT, tax reform, shelf project, ESOP

51.

Where's the Rest of Me?: Ryan's Republican Wish List

Calvin H. Johnson, Where’s the Rest of Me?: Ryan’s Republican Wish List, 152 Tax Notes 105 (July 4, 2016)
Number of pages: 5 Posted: 21 Jul 2016 Last Revised: 27 Aug 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 107 (429,044)

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52.

Debate on Carried Interest

157 Tax Notes 1597, (Dec. 11, 2017), FSU College of Law, Public Law Research Paper No. 897, FSU College of Law, Law, Business & Economics Paper No. 18-14, U of Texas Law, Public Law Research Paper
Number of pages: 22 Posted: 29 Oct 2018
Calvin H. Johnson, Jeffrey H. Kahn and Douglas A. Kahn
University of Texas at Austin - School of Law, Harry M. Walborsky Professor, Florida State University College of Law; Associate Dean, Business Program and University of Michigan Law School
Downloads 106 (431,839)

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53.

Wherein Our Duty Lies

Tax Notes, Vol. 159, No. 13, 2018, U of Texas Law, Public Law Research Paper
Number of pages: 5 Posted: 07 Aug 2018
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 106 (431,839)

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54.

Why Our Constitution Should Not Be Adopted?? A Review of Michael Klarman’s The Framers’ Coup: The Making of the United States Constitution (Oxford 2016)

U of Texas Law, Public Law Research Paper No. 685
Number of pages: 7 Posted: 07 Nov 2017 Last Revised: 05 Dec 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 106 (431,839)

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55.

Settle Withholding by the Dollars, Not Control

Tax Notes, p. 949, August 20, 2012, The Shelf Project, Forthcoming, U of Texas Law, Law and Econ Research Paper No. 233
Number of pages: 11 Posted: 25 Aug 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 106 (431,839)
Citation 1

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56.

Amazing Waste: Tax Subsidies to Qualified Retirement Plans

Tax Notes, Vol. 144, No. 727, 2014, U of Texas Law, Public Law Research Paper No. 619
Number of pages: 19 Posted: 24 Aug 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 104 (437,815)

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57.

States Rights? What States’ Rights?: Implying Limitations on the Federal Government from the Overall Design

Buffalo Law Review Vol. 57, p. 225, No. 2009
Number of pages: 54 Posted: 06 Jun 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 104 (437,815)

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58.

Depreciation Policy During Carnival: The New 50 Percent Bonus Depreciation

Tax Notes, Forthcoming
Number of pages: 9 Posted: 09 Sep 2004
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 104 (437,815)

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Tax Depreciation, Bonus Depreciation, ACRS Depreciation

59.

Taxing GE and Other Masters of the Universe

Tax Notes, Vol. 132, p. 175, July 2011, U of Texas Law, Law and Econ Research Paper No. 226
Number of pages: 12 Posted: 06 Jun 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 103 (440,832)

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60.

Repatriation Tax: Are We Churchill or Chamberlain?

Tax Notes, Vol. 144, No. 12, 2014, U of Texas Law, Public Law Research Paper No. 620
Number of pages: 8 Posted: 10 Oct 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 102 (443,877)

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61.

Taxing the Publicly Traded Stock in a Corporate Acquisition

Tax Notes, Vol. 124, No. 13, pp. 1363-1370, September 28, 2009, The Shelf Project
Number of pages: 9 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 99 (453,013)
Citation 1

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tax, corporate reorganization, boot

62.

Fixing Capital Gains at the Core

Tax Notes, Vol. 125, p. 1221, December 14, 2009, The Shelf Project
Number of pages: 9 Posted: 21 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 98 (456,017)

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tax reform, capital gains

63.

Inventory of Shelf Projects by Subject Matter (May 2012)

The Shelf Project
Number of pages: 17 Posted: 30 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 97 (459,094)

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64.
Downloads 95 (465,444)

Omnibus Capitalization Proposals

Tax Notes, Vol. 124, No. 11, pp. 1121-1130, September 14, 2009, The Shelf Project
Number of pages: 11 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 53 (653,220)

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capiltalization investment expenditures

Omnibus Capitalization Proposals

Tax Notes, Vol. 124, p. 1121, September 2009, The Shelf Project
Number of pages: 10 Posted: 30 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 42 (723,296)

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65.

Was it Lost?: Personal Deductions Under Tax Reform

Southern Methodist University Law Review, Vol. 59, 2006, U of Texas Law, Law and Econ Research Paper No. 91
Number of pages: 33 Posted: 05 Oct 2006
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 93 (471,869)

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tax, donation

66.

Elephant in the Parlor: Repeal of Stepup in Basis at Death

Tax Notes, Vol. 121, p. 1181, December 8, 2008, The Shelf Project
Number of pages: 9 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 92 (475,124)

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tax reform,basis at death

67.

Determine Dividends by Shareholder Gains, Not Corporate E&P

163 Tax Notes 871 (May 6, 2019)
Number of pages: 10 Posted: 08 Jul 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 90 (481,666)

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Taxation Corporate Dividends

68.

Passing Estate Tax Values Through the Eye of the Needle

Tax Notes, Vol. 132, p. 939, August 2011, U of Texas Law, Law and Econ Research Paper No. 214, The Shelf Project
Number of pages: 10 Posted: 08 Sep 2011
Calvin H. Johnson and Joseph M. Dodge
University of Texas at Austin - School of Law and Florida State University - College of Law
Downloads 90 (484,996)

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69.

Fixing the Constitutional Absurdity of the Apportionment of Direct Tax

Constitutional Commentary, Vol. 21, pp. 295-349, 2004, U of Texas Law, Public Law Research Paper No. 76
Number of pages: 57 Posted: 16 Nov 2005
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 90 (481,666)

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70.

Impose Capital Gain Tax on Like-Kind Exchanges

The Shelf Project, Tax Notes, Vol. 121, p. 475, October 27, 2008
Number of pages: 6 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 87 (491,849)

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tax reform,like-kind exchanges

71.

Madison's Denial

Constitutional Commentary, Vol. 34 (2019), U of Texas Law, Public Law Research Paper
Number of pages: 28 Posted: 20 Feb 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 86 (495,378)

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72.

Better Twice Measured: Partner Basis from Partnership Debt

Tax Notes, Vol. 146, No. 9, 2015, U of Texas Law, Public Law Research Paper No. UTPUB628
Number of pages: 23 Posted: 27 May 2015
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 84 (502,585)
Citation 1

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73.

Taxation of the Really Big House

The Shelf Project, Tax Notes, Vol. 122, p. 915, February 16, 2009
Number of pages: 9 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 81 (513,608)

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tax reform,housing, mortgage deduction, property tax deduction

74.

Wasting $2.5 Trillion on No-Growth Capital

Tax Notes, Vol. 158, No. 7, 2018, U of Texas Law, Public Law Research Paper
Number of pages: 6 Posted: 09 Apr 2018
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 79 (521,192)

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The Incredible Shrinking Domain of Corporate Stock

U of Texas Law and Economics Research Paper No. 028
Number of pages: 18 Posted: 03 Jun 2004
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 79 (527,015)

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corporate stock, tax

The Incredible Shrinking Domain of Corporate Stock

Posted: 14 May 2004
Calvin H. Johnson
University of Texas at Austin - School of Law

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76.

Two Years of the Shelf Project

Tax Notes, Vol. 126, p. 513, January 2010
Number of pages: 8 Posted: 03 Feb 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 78 (525,124)

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tax reform

77.

Gain Realized in Life Should Not Disappear by a Step-Up in Basis

Tax Notes, Vol. 156, No. 10, 2017
Number of pages: 9 Posted: 10 Nov 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 77 (529,088)
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78.

End Tax Floats by Taxing Receivables or Deferring Payables

Tax Notes, Vol. 129, p. 1243, December, 2010, The Shelf Project
Number of pages: 14 Posted: 30 May 2012
Calvin H. Johnson and Gregg D. Polsky
University of Texas at Austin - School of Law and University of Georgia School of Law
Downloads 77 (529,088)

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79.

Timber!

Tax Notes, Vol. 125, No. 7, pp. 801-804, November 16, 2009, The Shelf Project
Number of pages: 5 Posted: 27 Nov 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 77 (529,088)

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tax, timber

80.

A Fair Income Tax on the Trillion-dollar Behemoths

171 Tax Notes Federal 1199
Number of pages: 12 Posted: 08 Jul 2021
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 76 (533,092)

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Capitalization of intangible investments; $6 trillion revenue

81.

Horse Losses and Other Pleasures

142 Tax Notes 1443 (March 31, 2014), U of Texas Law, Public Law Research Paper No. 558
Number of pages: 16 Posted: 17 Apr 2014
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 76 (533,092)

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82.

Altera's Bonkers Accounting: Stock Compensation Really is a Cost

161 Tax Notes 339 (October 15, 2018)
Number of pages: 9 Posted: 11 Dec 2018
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 75 (537,217)

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83.

Payout by Charities Over 50 Years

Tax Notes, Vol. 132, p. 1161, September 2011, U of Texas Law, Law and Econ Research Paper No. 217, The Shelf Project
Number of pages: 8 Posted: 19 Sep 2011
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 75 (537,217)
Citation 1

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84.

'Impost Begat Convention': New York's Ratification of the Constitution

U of Texas Law, Public Law Research Paper No. 642
Number of pages: 36 Posted: 20 Apr 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 74 (541,289)

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85.

No Deductions for Tax Planning and Controversy Costs

Tax Notes, 2010, U of Texas Law, Law and Econ Research Paper No. 192, The Shelf Project
Number of pages: 8 Posted: 16 Nov 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 73 (545,389)
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86.

Don't Mess with Texas: Uniform Internet Sales Tax after Wayfair?

90 State Tax Notes 625 (Nov. 12, 2018), U of Texas Law, Public Law Research Paper No. 703
Number of pages: 8 Posted: 20 Dec 2018 Last Revised: 13 May 2020
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 71 (553,773)

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87.

Deferred Payment Sales

The Shelf Project, Tax Notes, Vol. 120, p. 157, July 14, 2008
Number of pages: 7 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 71 (553,773)

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tax reform,deferred payment sale

88.

Counterpoint: A Sur-Rebuttal to Professor Jensen on the Constitutionality of an Unapportioned Wealth Tax

39(1) ABA Tax Times (Nov. 2019)
Number of pages: 4 Posted: 18 Nov 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 70 (558,039)

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apportionment of direct tax, constitutionality of wealth tax

89.

Closing Deferred Revenue

The Shelf Project, Tax Notes, Vol. 121, p. 965, November 24, 2008
Number of pages: 8 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 70 (558,039)

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tax reform,deferred revenue

90.

Ordinary Medical Expenses

The Shelf Project, Tax Notes, U of Texas Law, Public Law Research Paper No. 543, U of Texas Law, Law and Econ Research Paper No. 543
Number of pages: 9 Posted: 20 Nov 2013 Last Revised: 22 Nov 2013
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 69 (562,343)

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91.

Ain’t Charity: Disallowing Deductions for Kept Resources

Tax Notes, Vol. 128, p. 545, August 2, 2010
Number of pages: 8 Posted: 20 Aug 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 69 (562,343)

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charitable deduction, tax reform

92.

Percentage Depletion of Imaginary Costs

Tax Notes, Vol. 122, No. 13, pp. 1619-1625, March 30, 2009, The Shelf Project
Number of pages: 8 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 68 (566,744)

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percentage depletion allowance

93.

An Employer-Level Proxy Tax on Fringe Benefits

Tax Notes, Vol. 123, No. 4, pp. 483-489, April 27, 2009, The Shelf Project
Number of pages: 8 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 67 (571,296)
Citation 1

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94.

The Effective Tax Ratio and the Undertaxation of Intangibles

Tax Notes, Vol. 121, No. 11, 2008
Number of pages: 15 Posted: 13 Dec 2008 Last Revised: 06 Aug 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 60 (603,880)

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95.

Corporate Meltdowns Caused by Compensatory Stock Options

Tax Notes, Vol. 131, p. 737, May 2011, The Shelf Project
Number of pages: 4 Posted: 31 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 58 (614,094)

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96.

Charles Beard and Three Barbie Dolls

Number of pages: 25 Posted: 08 Mar 2015
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 57 (619,232)

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97.

Codification of General Disallowance of Artificial Losses

Tax Notes, Vol. 122, p. 1389, March 2009, The Shelf Project
Number of pages: 4 Posted: 30 May 2012
Calvin H. Johnson and Lawrence Zelenak
University of Texas at Austin - School of Law and Duke University School of Law
Downloads 57 (619,232)

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98.

No Deduction for Tax Planning and Controversy Costs

Tax Notes, Vol. 129, p. 333, October 2010, The Shelf Project
Number of pages: 8 Posted: 30 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 57 (619,232)

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99.

Business and Casualty Losses When Basis Has Not Been Lost

The Shelf Project, Tax Notes, Vol. 120, p. 357, July 28, 2008
Number of pages: 4 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 56 (624,410)
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tax reform, casualty loss,business loss

100.

Wash Sales with Replacement by Related Parties

The Shelf Project, Tax Notes, Vol. 120, p. 1325, September 29, 2008
Number of pages: 7 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 56 (624,410)
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tax reform, wash sales

101.

Step-Up at Death but Not for Income

Tax Notes, Vol. 156, 2017, U of Texas Law, Public Law Research Paper No. 686
Number of pages: 7 Posted: 10 Nov 2017 Last Revised: 06 Dec 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 55 (629,624)

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102.

What is Very Wrong in Obama's Business Tax Reform

Tax Notes, Vol. 146, No. 5, 2015
Number of pages: 8 Posted: 08 Mar 2015
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 55 (629,624)

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103.

Transition to Territoriality Without Plunder: A $725 Billion Tax

Tax Notes, Vol. 154, No. 9, p. 1135, February 29, 2017, U of Texas Law, Public Law Research Paper No. 672
Number of pages: 7 Posted: 08 May 2017 Last Revised: 28 Sep 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 52 (646,079)

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104.

FASB and Guarantees of Variable Interest Entities

Tax Notes, Vol. 154, No. 4, 2017, U of Texas Law, Public Law Research Paper
Number of pages: 5 Posted: 06 Mar 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 51 (651,598)

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105.

End Tax Subsidy from Abandonments and Swaps

Tax Notes, Vol. 152, No. 1171, 2016, The Shelf Project, U of Texas Law, Public Law Research Paper
Number of pages: 7 Posted: 06 Nov 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 48 (668,704)

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106.

Nyet, Nein, Non, No to Capital Gain on Depreciable Property

Tax Notes, Vol. 152, No. 1455, 2016, The Shelf Project, U of Texas Law, Public Law Research Paper No. 662
Number of pages: 5 Posted: 06 Nov 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 48 (668,704)

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107.

Repeal Roth Retirement Plans to Increase National Savings

Tax Notes, Vol. 128, p. 773, August 2010, The Shelf Project
Number of pages: 9 Posted: 30 May 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 48 (668,704)

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108.

End Tax-Free Monetization of Wealth

The Shelf Project, Tax Notes, Vol. 119, p. 1361, June 30, 2008
Number of pages: 7 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 47 (674,764)
Citation 1

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tax reform

109.

Cut Negative Tax out of Step-Up at Death

156 Tax Notes 741 (Aug. 7, 2017) , U of Texas Law, Public Law Research Paper
Number of pages: 13 Posted: 07 Dec 2017
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 46 (680,767)

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110.

Cleaning Compensation for Services Out of Capital Gain

TAX NOTES, Vol. 126, p. 233, January 2010
Number of pages: 9 Posted: 21 Jan 2010
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 46 (680,767)
Citation 1

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tax reform

111.

Corporate Distributions from Earnings and Beyond

Tax Notes, Vol. 127, p. 813, 2010, The Shelf Project
Number of pages: 9 Posted: 04 Jun 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 44 (693,344)

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112.

Simplification by Repeal of the One-Year Rule for Prepayments

Tax Notes, Vol. 124, No. 8, pp. 809-814, August 24, 2009, The Shelf Project
Number of pages: 7 Posted: 03 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 44 (693,344)
Citation 2

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tax, prepayments

113.

Extender Tax Provisions

U of Texas Law, Law and Econ Research Paper No. 221, U of Texas Law, Public Law Research Paper No. 211
Number of pages: 26 Posted: 23 Feb 2012
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 43 (699,602)

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114.

End Identification of Stock Certificates

The Shelf Project, Tax Notes, Vol. 119, p. 1171, June 16, 2008
Number of pages: 6 Posted: 09 Dec 2009
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 42 (706,101)

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tax reform,basis,stock sales

115.

Deficits by Tier: Payback of the 2017 Tax Act by Wealth

164 Tax Notes Federal 1893, September 2019
Number of pages: 9 Posted: 22 Oct 2019
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 41 (712,893)

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2017 Tax Cut, deficits

116.

Point The Supreme Court’s Statutory Interpretation in Gitlitz: A Failed Approach to Interpretation and a Bad Decision

ABA Tax Times Fall 2020
Number of pages: 7 Posted: 24 Feb 2021
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 40 (719,753)

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Statutory interpretation; tax substance over form

117.

Death and the Tax Benefit Rule

Tax Notes, May 2017, U of Texas Law, Public Law Research Paper No. 668
Number of pages: 9 Posted: 13 Nov 2017 Last Revised: 18 Jan 2018
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 38 (733,540)

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118.

Sale of Long-Term Electricity Supply Contract is Ordinary Gain

Tax Notes, Vol. 152, No. 887 (August 8, 2016)
Number of pages: 6 Posted: 27 Aug 2016
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 31 (785,519)

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119.

Return to Civic Virtue: Tax Meals, 170 Tax Notes Federal 1105

Number of pages: 7 Posted: 24 Mar 2021
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 28 (809,633)

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income taxation of meals

120.

The Supreme Court's Statutory Interpretation in Gitlitz: A Failed Approach to Interpretation and a Bad Decision

ABA Tax Section, Tax Times, November 2020
Number of pages: 7 Posted: 18 Mar 2021
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 20 (880,532)

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tax substance over form, statutory interpretion, correcting absurdity in tax

121.

Slavery, Federalism and the Textual Power for the General Welfare

Number of pages: 30 Posted: 09 Feb 2022
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 15 (929,312)

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Slavery and the Constitution, General Welfare Power, Federalism

122.

Taxing the Consumption of Capital Gains

Virginia Tax Review, Vol. 28, No. 477, 2009, U of Texas Law, Law and Econ Research Paper No. 163
Posted: 30 Oct 2009
Calvin H. Johnson
University of Texas at Austin - School of Law

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123.

The Bush 35 Percent Flat Tax on Distributions from Public Corporations

Posted: 23 Apr 2004
Calvin H. Johnson
University of Texas at Austin - School of Law

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Dividend tax, corporate integration

124.

Destroying Tax Base: The Proposed Indopco Capitalization Regulations

Posted: 30 May 2003
Calvin H. Johnson
University of Texas at Austin - School of Law

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125.

Accounting in Favor of Investors

Cardozo Law Review, Vol. 19, No. 2 (1997) (Symposium on the Essays of Warren Buffett).
Posted: 02 May 1997
Calvin H. Johnson
University of Texas at Austin - School of Law

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Other Papers (1)

Total Downloads: 18
1.

Cut Off the Equity Funds

Tax Notes Federal, Volume 176, September 5, 2022
Number of pages: 2 Posted: 11 Oct 2022
Calvin H. Johnson
University of Texas at Austin - School of Law
Downloads 18

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Equity funds, interest deduction, acquisition indebtedness