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Corporations Partnerships Estates and Trusts 44th Edition William A Raabe James C Young Annette Nellen William H Hoffman JR David M
Corporations Partnerships Estates and Trusts 44th Edition William A Raabe James C Young Annette Nellen William H Hoffman JR David M
Corporations Partnerships Estates and Trusts 44th Edition William A Raabe James C Young Annette Nellen William H Hoffman JR David M
CHAPTER
1
DISCUSSION QUESTIONS
1. (LO 1) When enacting tax legislation, Congress often is guided by the concept of revenue
neutrality so that any changes neither increase nor decrease the net revenues raised under the
prior rules. Revenue neutrality does not mean that any one taxpayer’s tax liability remains the
same. Since this liability depends on the circumstances involved, one taxpayer’s increased
tax liability could be another’s tax saving. Revenue-neutral tax reform does not reduce
deficits, but at least it does not aggravate the problem.
2. (LO 2) Economic, social, equity, and political factors play a significant role in the formulation
of tax laws. Furthermore, the Treasury Department, the IRS, and the courts have had impacts
on the evolution of tax laws. For example, control of the economy has been an important
economic consideration in passing a number of laws (e.g., rapid depreciation, changes in
tax rates). But ultimately the tax law is written by Congress.
3. (LO 2) The tax law encourages technological progress by allowing immediate (or
accelerated)
deductions and tax credits for research and development expenditures.
4. (LO 2) Saving leads to capital formation and thus makes funds available to finance home
construction and industrial expansion. For example, the tax laws provide incentives to
encourage savings by giving private retirement plans preferential treatment.
5. (LO 2)
1-1
then, is not what appears fair or unfair to any one taxpayer or group of taxpayers. Equity is,
instead, what the tax law recognizes.
7. (LO 2) This deduction can be explained by social considerations. The deduction shifts some
of the financial and administrative burden of socially desirable programs from the public (the
government) sector to the private (the citizens) sector.
8. (LO 2) Preferential treatment of private retirement plans encourages saving. Not
only are contributions to Keogh (H.R. 10) plans and certain Individual Retirement Accounts
(IRA) deductible, but income from these contributions accumulates on a tax-free basis.
9. (LO 2) The availability of percentage depletion on the extraction and sale of oil and gas and
specified mineral deposits and a write-off (rather than capitalization) of certain exploration
costs encourage the development of natural resources.
10. (LO 2) Favorable treatment of corporate reorganizations provides an economic benefit. By
allowing corporations to combine and split without adverse consequences, corporations are in
a position to reduce their taxes and possibly more effectively compete with other businesses
(both nationally and internationally).
11. (LO 2) Although the major objective of the Federal tax law is the raising of revenue,
other considerations explain many provisions. In particular, economic, social, equity, and
political factors play a significant role. Added to these factors is the impact the Treasury
Department, the Internal Revenue Service, and the courts have had and will continue to have
on the evolution of Federal tax law.
12. (LO 2) The deduction allowed for Federal income tax purposes for state and local income taxes
is not designed to neutralize the effect of multiple taxation on the same income. At most, this
deduction provides only partial relief. The $10,000 overall limitation on state and local taxes
also reduces the tax benefit of these taxes. Only allowing a full tax credit would achieve
complete neutrality.
a. With the standard deduction, a taxpayer is indirectly obtaining the benefit of a deduction
for any state or local income taxes he or she may have paid. The standard deduction is
in lieu of itemized deductions, which include any allowed deductions for state and local
income taxes.
b. If the taxpayer is in the 10% tax bracket, $1 of a deduction for state or local taxes
would save
$0.10 of Federal income tax liability. In the 32% tax bracket, the saving becomes
$0.32. The deduction approach (as opposed to the allowance of a credit) favors high-
bracket taxpayers.
13. (LO 2) Under the general rule, a transfer of a partnership’s assets to a new corporation could
result in a taxable gain. However, if certain conditions are met, § 351 postpones the recognition
of any gain (or loss) on the transfer of property by Heather to a controlled corporation (see
Example 4).
The wherewithal to pay concept recognizes the inequity of taxing a transaction when Heather
lacks the means with which to pay any tax. Besides, Heather’s economic position would not
change significantly should the transfer occur. Heather owned the assets before the transfer
and still would own the assets after a transfer to a controlled corporation. See Chapter 4
for a more detailed discussion of § 351.
Language: English
Transcriber’s Notes
The cover image was provided by the transcriber and is placed in the public
domain.
The text may show quotations within quotations, all set off by similar quote
marks. The inner quotations have been changed to alternate quote marks for
improved readability.
This book was written in a period when many words had not become
standardized in their spelling. Words may have multiple spelling variations
or inconsistent hyphenation in the text. These have been left unchanged
unless indicated with a Transcriber’s Note.
The symbol ‘‡’ indicates the description in parenthesis has been added to an
illustration. This may be needed if there is no caption or if the caption does
not describe the image adequately.
Footnotes are identified in the text with a superscript number and are shown
immediately below the paragraph in which they appear.
Transcriber’s Notes are used when making corrections to the text or to provide
additional information for the modern reader. These notes are identified by
♦♠♥♣ symbols in the text and are shown immediately below the paragraph
in which they appear.
Baron E de R
BY
M. A M
1600‒1918
BY
NAHUM SOKOLOW
WITH AN INTRODUCTION BY
IN TWO VOLUMES
VOL II.
WITH AN INTRODUCTION BY
M. STÉPHEN PICHON
MINISTER OF FOREIGN AFFAIRS FOR FRANCE
1919
PREFATORY NOTE
T present volume contains the continuation and documentation of
Volume I.
The developments in the Zionist Movement during the War are dealt
with in a separate account, which is not claimed to be, in the proper sense of
the word, an historical study, but an account of recent activities up to the
Peace Conference.
The appendices contain not only the text of documents referred to in the
body of the book, many of them hitherto unpublished, but also essays on
subjects related to the main purpose of the work—for instance, Jewish art,
and Hebrew literature—and notes of a bibliographical or critical character.
It is desired to point out that the nature of the subject with which this
work deals rendered it inevitable that it should to some extent assume an
encyclopædic rather than a narrative character. The innumerable sources
from which Zionism draws its being, the geographical dispersion of the
Jewish people, the many events and phenomena outside of the life of the
Jewish people which have had and still have their bearing on the
development of the Jewish National idea, give it inevitably the form that it
has assumed. The author is well aware that the History of Zionism as
narrated in these pages does not appear as altogether a symmetrical
structure. Some periods dealt with in the story are somewhat disjointed, and
as a necessary consequence the record of those periods reflects the same
character. A writer who cared more for the form than for the correctness of
the narrative would in such a case have recourse to his imagination in order
to fill in the blanks. The present author has not, however, done so. He has
attempted rather to let Zionism appear as it really was in the different
countries and epochs with which he has dealt. Where his narrative is
fragmentary events were fragmentary. In the earliest periods the different
elements of Zionism were sometimes completely detached from one
another. An exact description of these therefore takes necessarily an
encyclopædic character. But Zionism develops as a unity, and at the end it
will be found to offer to the reader a united picture.
The plan which the author has followed falls under three headings:—
In accordance with this plan this history begins in the year 1600,
although the history of Zionism in reality opened much earlier, even
perhaps at the beginning of the Jewish history of the countries dealt with.
Publication of an index to the work might well have been deferred until
these volumes had been completed, but the author thinks that he ought not
to delay one any longer. At the end of the present volume, therefore, the
reader will find a thorough index of persons and of subjects, for which Mr.
Jacob Mann, . ., is responsible and to whom he hereby tenders his thanks.
C’est dire l’écho que ne pourra manquer d’éveiller chez les Français la
voix éloquente du représentant le plus autorisé du Sionisme. Monsieur
Sokolow, mettant au service de son idéal, un talent qui n’en est plus à son
premier essai, s’attache à nous retracer l’histoire des doctrines au triomphe
desquelles il n’a cessé de consacrer le meilleur de ses forces. Sachant
combien il importe, aujourd’hui, de démontrer historiquement les origines
et les antécédents des idées que l’on professe, il a voulu nous exposer les
titres que possède le Sionisme à s’imposer à l’attention des Alliés, au
moment où ceux-ci procèdent à une reconstitution du monde entier.
Monsieur Sokolow, dont la foi dans le succès final de nos armes ne connut
jamais de défaillances, possède une foi au moins égale dans l’esprit de
justice qui préside à l’œuvre de la Conférence de la Paix. Les sympathies et
les concours précieux qu’il a su trouver chez nos amis Britanniques, et dont
Mr. Balfour lui renouvelle ici-même l’assurance la plus formelle, sont aux
protagonistes du Sionisme un sûr garant de l’accueil que la France réserve à
leur généreuse initiative.
Non seulement, en effet la race juive n’a cessé d’être, au cours des
siècles, persécutée, décimée, poursuivie sans trêve par une haine incapable
de désarmer; plus malheureuse encore que tant d’autres peuples opprimés,
qui ont pu conserver au moins un symbôle de leur grand passé, les Juifs
n’ont pu sauver ce dernier vestige. D’autres qu’eux mêmes sont devenus les
maîtres de la Judée. Dispersés à travers le monde, beaucoup aspirent
aujourd’hui plus que jamais à reprendre la chaîne brisée par tant de
conquérants successifs, de leurs traditions ethniques et religieuses: ils
pensent aussi qu’une telle restauration n’est possible qu’appuyée sur des
réalités, c’est à dire, en l’espèce, sur un foyer moral national reconstitué au
milieu des ruines de l’antique Judée. Qui donc, sans avoir perdu les plus
élémentaires sentiments d’humanité et de justice, pourrait refuser aux exilés
de revendiquer leur place, au même titre que les autres éléments indigènes,
dans cette Palestine où un contrôle collectif des Puissances européennes
assurera désormais à chacun le respect de ses droits les plus sacrés?
INTRODUCTION M. S P
CONTENTS V II.
ILLUSTRATIONS V II.
CHAPTER XLIX . F S F
C
Chovevé Zion and Zionists in England—Louis Loewe—Nathan Marcus Adler
—Albert Löwy—Abraham Benisch—The Rev. M. J. Raphall—Dr. M. Gaster
—Rabbi Samuel Mohilewer—English representation at the Second and Third
Congresses—The Fourth Congress in London.
CHAPTER XLIX . T D H
England and Zionism—Sir B. Arnold in the Spectator—Cardinal Vaughan—
Lord Rosebery—The death of Herzl—David Wolffsohn—Prof. Otto Warburg
—Zionism in the smaller states.
CHAPTER XLIX . T P
The year 1906—Pogroms—Emigration—Conder and his activities—An
Emigration Conference—The Eighth Congress—The question of the
Headquarters.
CHAPTER XLIX . T D W
1910‒14—The Tenth and Eleventh Congresses—Death of Wolffsohn.
CHAPTER XLIX . O E W
Baron Edmond de Rothschild in Palestine—Sir John Gray Hill—Professor S.
Schechter—South African Statesmen—A Canadian Statesman—Christian
religious literature again.
⭘ General Survey
⭘ Zionist Propaganda in Wartime
⭘ Conferences
⭘ The Jewish National Fund
⭘ Zionism and Jewish Relief Work
⭘ The Russian Revolution
⭘ Political Activities in England and the Allied Countries
⭘ Conference of English Zionist Federation in 1917
⭘ Zionism and Public Opinion in England
⭘ Co-ordination of Zionists’ Reports
⭘ The British Declaration and its Reception
⭘ London Opera House Demonstration
⭘ Manifesto to the Jewish People
⭘ Declarations of the Entente Governments
APPENDICES—
ADDENDA
CORRIGENDA
BOOKS CONSULTED
INDEX
ILLUSTRATIONS TO
VOL. II.
○B E R
○L .-C .S M S ,B ., M.P.
○R .H .A J. B , M.P.
○G .S E H. H. A
○ M. S. J. M. P
○ M. J C
○ H.E. P B
○ H.E. B S S
○ M. A. F. J. R
○ M. G. E. B. C
○P T W W
○R .H .D L G , M.P.
○L F S H U ,
J
○N R .
○T K C , 5644 = 1884