The Evolution to and Review of Proposed Regulations to the Economic Performance Requirements of Section 461(h)

Author

Richard H. Fennell, Fontbonne College

Year of Award

1991

Degree

Master of Science in Taxation (MST)

College

College of Business & Professional Studies

Degree Program

Taxation

Department

Business Administration

Keywords

IRS, tax code, congress

Abstract

I have chosen for my Capstone Research Project the topic of The Proposed Regulations to the Economic Performance Requirements of Section 461(h). My reason for choosing this topic is because of the tremendous amount of negative criticism that has been generated since the proposed regulations were published on June 7, 1990.

This paper reviews the historical background of our taxing system from the inception through the progression to our modern-day very complex and burdensome rules contained in the Code. The major focus is on the development of the all-events test, the addition of the economic performance rules to the test, and the potential impact of the Proposed Regulations of Section 461(h). Some of the major controversial issues are analyzed and certain alternatives are suggested. Numerous criticisms are directed toward the Service for exceeding Congressional intent by using the time value of money problem as a means to remedy other perceived abuses.

Document Type

Restricted Thesis

Recommended Citation

Fennell, Richard H., "The Evolution to and Review of Proposed Regulations to the Economic Performance Requirements of Section 461(h)" (1991). All Theses, Dissertations, and Capstone Projects. 419.
https://griffinshare.fontbonne.edu/all-etds/419