All Theses, Dissertations, and Capstone Projects

Year of Award



Master of Science in Taxation (MST)


College of Business & Professional Studies

Degree Program



Business Administration


IRS, tax code, congress


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.

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In Copyright