Don’t Burst the Bubble: An Analysis of the First-Time Homebuyer Credit and Its Use as an Economic Policy Tool

In 2008, faced with a looming real estate crisis, Congress hastily acted to stabilize the economy by offering a first-time homebuyer credit. This tax credit was trumpeted as a solution to the excess inventory of homes for sale and to stop the free-fall in home values. The credit, however, failed to deliver on its promises. By analyzing the first-time homebuyer credit, its creation, its implementation and its economic impact, this Article concludes that, when compared to alternative policy solutions, Congress erred in using the tax code to implement a first-time homebuyer credit

Paying the IRS Whistleblower: A Critical Analysis of Collected Proceeds

Congressional changes to the IRS Whistleblower Program were intended to induce more participation in the program by allowing larger incentives and greater certainty that whistleblowers would be paid. Since the Program was amended, tax whistleblower tips have increased 76 percent1 and revenue collected due to whistleblowers has increased 79 percent.2 Despite a rise in tips and revenue collected, whistleblower payments have not increased. In fact, the number of tax whistleblower awards paid has decreased 44 percent.3 We hypothesize that this trend is due to the administration of the program but also to the interpretation of “collected proceeds.” Collected proceeds are tax revenues collected due to a specific whistleblower tip and comprise the pool of money from which a tax whistleblower award is made. While scholarship exists examining the Whistleblower Program amendments and their effects, no scholar has critically examined the crux of the Whistleblower Program: what should constitute collected proceeds

Lost Opportunities: The Underuse of Tax Whistleblowers

Legal literature on whistleblower programs often assumes an agency’s ability to effectively use a whistleblower tip. This article challenges that assumption in the context of tax enforcement by exposing the Internal Revenue Service’s dismal performance. The article uses Fourth Amendment jurisprudence, taxpayer privacy law, as well as whistleblower and tax enforcement literature to propose a new approach to using information from tax whistleblowers

Should Religious Organizations Worry about IRS Audits?

A great deal of media attention has focused on recent perceived financial abuses of churches and religious organizations. Cases of fraud within religious organizations have fueled the public perception that churches require some form of monitoring to prevent financial abuse. However, the IRS has limited authority to audit religious organizations under section 7611, and the results of such audits are generally unavailable to the public. Through a Freedom of Information Act request, we obtained the outcomes of all section 7611 IRS audits of religious organizations conducted between 2001 and 2010. We found that although the number of both churches and nonchurch-related organizations (NCROs) increased significantly during the period examined, the number of IRS audits did not rise. We also analyzed religious organizations’ chances of being selected for an IRS examination and the likely outcome of an examination. In most cases the audits ended with no change to the organization’s status, or a delinquent tax return was secured. This information is useful for churches that may face or are currently under IRS examination. Further, this information can help tax practitioners assess examination outcomes and advise clients

NOL Poison Pills: Using Corporate Law for Tax Purposes

Hundreds of thousands of corporations report net operating loss (NOL) carryovers every year.1 Corporations, with the benefit of NOL rules, may turn disappointing losses into favorable tax results. During economic recovery, corporations are in better position to fully utilize the benefits of NOLs generated in prior years. NOL usage is not without peril, however. Corporations should carefully monitor corporate ownership changes to ensure that NOLs are not lost to the NOL trafficking rules. Under the NOL trafficking rules, excessive shareholder turnover triggers substantial NOL limitations. Unfortunately, corporations are not in control of their shareholder turnover, and therefore not in complete control of their NOLs. To maintain NOL control, corporate tax planning may utilize defensive tactics found in corporate law, including an NOL poison pill plan. This article discusses the motivations, benefits and consequences of NOL poison pill plans

Representation of neurodivergence in fiction books:Exploring neurodivergent young peoples' perspectives

In recent years, there has been growing awareness of the importance of representation in fiction books, to ensure all children and young people can see themselves reflected in what they read. Much of this work has focused, importantly, on increasing ethnic representation, yet there has been much less exploration of the representation of other minority experiences, such as those of neurodivergent young people, and how these are perceived by neurodivergent young people themselves. This article provides new insights into neurodivergent young people's perceptions of representation of neurodivergence in fiction books (and other text types) based on semi-structured interviews with 16 neurodivergent young people (aged 14 to 17 year olds) from 2 high schools in Scotland. Using an inductive data-driven thematic analysis process, three themes were identified: (1) representation of neurodivergence should be complex, realistic, and positive; (2) representation of neurodivergence should be normalised; (3) representation of neurodivergence beyond books is important. Each of these themes is explored in detail, followed by implications for future research, practice and the publishing of Young Adult fiction.</p

Pro-maturational effects of human iPSC-derived cortical astrocytes upon iPSC-derived cortical neurons

Astrocytes influence neuronal maturation and function by providing trophic support, regulating the extracellular environment, andmodulating signaling at synapses. The emergence of induced pluripotent stem cell (iPSC) technology offers a human system with whichto validate and re-evaluate insights from animal studies. Here, we set out to examine interactions between human astrocytes and neuronsderived from a common cortical progenitor pool, thereby recapitulating aspects ofin vivocortical development. We show that the corticaliPSC-derived astrocytesexhibit many of the molecular and functional hallmarks of astrocytes. Furthermore, optogenetic and electrophys-iological co-culture experiments reveal that the iPSC-astrocytes can actively modulate ongoing synaptic transmission and exertpro-maturational effects upon developing networks of iPSC-derived cortical neurons. Finally, transcriptomic analyses implicate syn-apse-associated extracellular signaling in the astrocytes’ pro-maturational effects upon the iPSC-derived neurons. This work helps laythe foundation for future investigations into astrocyte-to-neuron interactions in human health and disease