Federal Income Tax

This book is designed for students taking a course in federal income tax, or for students in an advanced tax course who seek an explanation of an area in the basic income tax system that they had not learned or had forgotten. The authors provide clear concise explanations of the tax principles that underlie the tax system. For example, the doctrines of anticipatory assignment of income, anticipation of income, realization and nonrecognition are discussed in detail. Other important concepts such as substance versus form, economic substance, and the recission doctrine are explained.

While the book does not discuss every statutory provision of the Code, many are examined and explained. For example, the operation of the capital gains provisions, the quasi-capital asset provision of section 1231, the medical expense provision, the nonrecognition provisions of sections 108, 1031 and 1033 are examined in detail. Not only is section 108 examined, but the larger topic of cancellation of indebtedness is discussed. The authors devote significant attention to sections 1031 and 1033 because those provisions are typical of nonrecognition statutes and prepare a student for the complex nonrecognition provisions the student will encounter in an advanced tax course. Depreciation and recapture of depreciation are examined in detail and their underlying principles are described.

In addition to textual discussion of statutes and basic tax concepts and principles, the authors have provided a number of illustrations to show how the various provisions of the Code operate. There is discussion of the tax policies that underlie statutory provisions and how the knowledge of those policies can help arrive at a proper construction and application of the statutes.