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University of Baltimore Law Review

Abstract

Whether income earned by an incorporated personal service business is taxable to the individual or to the corporation is often the subject of reallocation proceedings brought by the Internal Revenue Service. In this article the author discusses the theories underlying income reallocation and the applicable Internal Revenue Code sections, focusing on section 482. The author analyzes in detail the factors courts consider in permitting or denying reallocation and identifies the conflicts among the circuits in the interpretation and application of section 482.

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