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Introduction. II. The Concept of Tax Justice. III. Criteria for Assessing Tax Justice. IV. Evidence of a Deferential Difference. A. The Abuse of Discretion Standard. B. The Abuse of Discretion Standard in Cases Involving Corporate Taxpayers. 1. Code Section 446 Cases. 2. Code Section 482 Cases. 3. Other Tax Court Abuse of Discretion Cases Involving Corporate Taxpayers. C. The Abuse of Discretion Standard in Cases Involving Individual Taxpayers. 1. Tax Court Review of Collections Cases. 2. Tax Court Review of Innocent Spouse "Equitable Relief Determinations. V. Social Science Explanations for the Deferential Difference. A. Sociological Theory and Social Psychology. 1. Homans' Theory. 2. The Progeny of Homans. 3. Prospect Theory. 4. Application of Sociological Theory to Judicial Deci...
...Commissioner, 60 the taxpayer was a contractor that used concrete, sand, drain rock, and various ..., Warranty Theory, Economic Loss, and the Privity Requirement: Once More into the Void, 67 B.U. L. R... New Institutionalism, at http://en.wikipedia.org/wiki/New_institutionalism (last visited Oct. 2...
...Wikipedia.org, Office of Technology Assessment, http://en.wi... for negligence even though there was no privity of contract between the parties). . (4) Jennifer S...
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