2,697 research outputs found

    Whistleblowers and Tax Enforcement: Using Inside Information to Close the Tax Gap

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    This article provides a critical look at the current scheme for rewarding tax informants, and in particular on the relatively new program for so-called whistleblower awards. Despite enhanced incentives for informants to come forward, tax award programs continue to operate in an environment based on discretion and uncertainty. Additional legislation is needed to clarify uncertainties and to limit eligibility for rewards, including protection of private tax return information from disclosure and preventing the government from incentivizing the breach of confidential obligations through offering rewards. Part II provides an overview of the IRS examination function and examines data involving the utility of informants in selecting returns for examination. Part III explores the statutory scheme for rewarding informants under I.R.C. § 7623, which was recently amended to include a separate whistleblower awards program affecting relatively large tax 20deficiencies. Part IV discusses some ethical and legal issues presented by the current whistleblower scheme. In particular, it identifies the need to protect professional obligations concerning confidentiality in the context of enhanced compliance goals. It argues for further clarification of reward parameters in order to provide appropriate incentives to help reduce the tax gap, while providing a clear message of deterrence for those who would violate professional or legal standards in making disclosures

    A Rational International Petroleum Regime for the 1990s

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    Mediation in Debtor/Creditor Relationships

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    Two states that have substantial interests in agricultural debtor/creditor relationships have attempted to limit the social and economic costs of prematurely terminating the debtor/creditor relationship. Iowa and Minnesota have adopted a statutory requirement that the creditor offer to submit to mediation prior to taking any debt collection action against an agricultural borrower. This Note argues that requiring creditors to offer mediation as a statutory prerequisite to debt collection is an effective means of reducing the social and economic costs of the premature termination of a debtor/creditor relationship in business contexts. Part I examines the conceptual foundations of the mediation process and analyzes the viability of extending mediation to debtor/creditor relationships, concluding that mediation can provide effective assistance in negotiating an alternative solution to repossession of collateral. Part II examines the mediation statutes of two agricultural states. An evaluation of empirical data from the Iowa Farmer/Creditor Mediation Service demonstrates that mediation has proved successful in resolving agricultural debtor/creditor disputes. Part III explores the feasibility of requiring mediation in debtor/creditor relationships outside of agriculture, including business and consumer loan contexts. Although mediation is probably more . appropriate and cost-effective in the case of business loans, possibilities also exist for application to consumer loans above a threshold amount

    Reflections on the Rule of Law and Clear Reflection of Income: What Constrains Discretion

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    A study in emulsions

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    An emulsion is a dispersion of one liquid in another liquid, the liquids being insoluble in each other. An emulsion consists of two phases, a continuous phase and a dispersed phase. The dispersed phase consists of tiny droplets or particles of one liquid which is completely surrounded by the other liquid comprising the continuous phase. One of the many factors affecting the stability of an emulsion is the size of the particle of the dispersed liquid. This study is concerned with one emulsion prepared by different mechanical devices and under different conditions. The units of equipment employed are Eppenbach Colloid Mill, Marco Homogenizer, Lightnin\u27 Mixer and Master Counter-current Mixer. Samples of the emulsion prepared by these methods will be retained for particle size determinations. All samples will be stored in a constant temperature room at 70° F. The ultimate aim of this study is to indicate the effectiveness of each of the emulsifying units studied. It is also desired to show how the particle size of the dispersed phase changes on aging. The stability of all samples was closely followed to discover any trends of instability. A search of the literature reveals only fragments of information concerning particle size analysis with regard to commercial preparation of emulsions. In the previous work on emulsions, standard laboratory methods of dispersion were usually used. It is hoped that this study combined with past and future studies will point to some definite mechanical system to produce the optimum commercial emulsion

    Technological Entanglements: Evidentiary and Ethical Considerations of Metadata in Interjurisdictional Litigation

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    Ethical and evidentiary rules governing the disclosure of confidential information are interrelated inmany respects. Nevertheless, these rules are generally developed independently through different legal channels.Different approaches to the inadvertent disclosure of confidential information have emerged, leading to uncertainresults in different jurisdictions. Uncertainty persists with regard to metadata available from electronic documentformats. This paper explores the tension between the competing approaches this emerging problem. It argues thatethical and evidentiary principles addressing the protection and discovery of metadata should be coordinated inorder to avoid creating incentives to maximize litigation costs

    Two Blue Eyes

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    https://digitalcommons.library.umaine.edu/mmb-vp/6632/thumbnail.jp

    Starlight

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    https://digitalcommons.library.umaine.edu/mmb-vp/6406/thumbnail.jp
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