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The Hidden Tax Trap of I.R.C. Section 6672
Get PDFTwo recent decisions of the United States Supreme Court examined section 6672 of the Internal Revenue Code. In Slodov v. United States, the Court expressed its views on the personal liability of business managers for unpaid taxes on employee wages. Discharging such liability because of the personal bankruptcy of the business manager was considered in United States v. Sotelo. The focal point of these cases—section 6672 of the Internal Revenue Code—provides for the potential liability of business managers for the employees’ share of taxes on wages (hereinafter trust fund taxes).
Although Slodov and Sotelo are helpful in understanding the scope and effect of section 6672, they do not lessen its hidden-trap character. The problem of tax deficiencies for unpaid taxes on employee wages is of enormous magnitude. In fiscal year 1976, there were 28,599 businesses delinquent in such taxes in the Chicago district of the IRSA. This statistic translated into $88.9 million of unpaid trust fund taxes which resulted in section 6672 penalty assessments against individuals connected with 535 of those businesses. Whether the exceptional remedy given the government under section 6672 to pursue individuals for the unpaid trust fund taxes is necessary to protect federal revenues cannot be answered without an examination of the applications of section 6672 and possible defenses to such penalty assessments. This article will examine these issues and comment on what should be done to reconcile the need to protect federal revenues with the need to be fair to individuals responsible for collecting and paying over trust fund taxes. Part I examines the question of who can be liable under section n6672, Part II examines the concept of “willfulness” which is a prerequisite for liability, and Part III examines possible reforms
[U.S. Govt., Engine Drawing Card, Sketch No. 6672]
No full textThis engine drawing card was created for the United States government, Class 14-50 1/4E. Section N-14 1/4E. Sketch 6672. Copy Spec. [field left blank]
[U.S. Govt., Engine Drawing Card, Sketch No. 6672]
No full textThis engine drawing card was created for the United States government, Class 14-50 1/4 E. Section N-14 1/4E. Sketch 6672. Copy Spec. [field left blank]
Going Beyond Counting First Authors in Author Co-citation Analysis
Get PDFThe present study examines one of the fundamental aspects of author co-citation analysis (ACA) - the way co-citation
counts are defined. Co-citation counting provides the data on which all subsequent statistical analyses and mappings
are based, and we compare ACA results based on two different types of co-citation counting - the traditional type that
only counts the first one among a cited work's authors on the one hand and a non-traditional type that takes into
account the first 5 authors of a cited work on the other hand. Results indicate that the picture produced through this non-traditional author co-citation counting contains more coherent author groups and is therefore considerably clearer. However, this picture represents fewer specialties in the research field being studied than that produced through the traditional first-author co-citation counting when the same number of top-ranked authors is selected and analyzed. Reasons for these effects are discussed
[Northern Suffolk, Locomotives 120-122, Erecting Card Drawing No. 6672]
No full textErecting card drawing for Norfolk Southern Railroad.This erecting drawing was created for Northern Suffolk Railroad Locomotives 120-122, Class 10-36 E 49-54. Erecting Card 6672. Index Number: 474A-85. For more technical details on this drawing, see Baldwin Erecting Drawings by Road Name: http://www.smu.edu/~/media/Site/libraries/degolyer/pdfs/BLW-EDWG-RoadName.pdf and/or Baldwin Erecting Drawings by Class Number: https://www.smu.edu/~/media/Site/libraries/degolyer/pdfs/BLW-EDWG-Class.pdf (Note: Search by Index Number or Erecting Card Number)
Variations on the Author
Get PDF“Variations on the Author” discusses two of Eduardo Coutinho’s recent films (Um Dia na Vida, from 2010, and Últimas Conversas, posthumously released in 2015) and their contribution to the general question of documentary authorship. The director’s filmography is characterized by a consistent yet self-effacing form of authorial self-inscription: Coutinho often features as an interviewer that rather than express opinions propels discourses; an interviewer that is good at listening. This mode of self-inscription characterizes him as an author who is not expressive but who is nonetheless markedly present on the screen. In Um Dia na Vida, however, Coutinho is completely absent form the image, while Últimas Conversas, on the contrary, includes a confessional prologue that moves the director from the margins to the center of his films. This article examines the ways in which these works stand out in the filmography of a director who offers new insights into the notion of cinematic authorship
Appropriate Similarity Measures for Author Cocitation Analysis
Get PDFWe provide a number of new insights into the methodological discussion about author cocitation analysis. We first argue that the use of the Pearson correlation for measuring the similarity between authors’ cocitation profiles is not very satisfactory. We then discuss what kind of similarity measures may be used as an alternative to the Pearson correlation. We consider three similarity measures in particular. One is the well-known cosine. The other two similarity measures have not been used before in the bibliometric literature. Finally, we show by means of an example that our findings have a high practical relevance.information science;Pearson correlation;cosine;similarity measure;author cocitation analysis
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Responsible person and lender liability for trust fund taxes ::Sections 6672 and 3505 /
No full text" ... discusses in detail the liability of responsible persons under [section] 6672 and of lenders and others who provide funds under [section] 3505 where there is a failure of an employer to remit trust fund taxes to the government.
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