After briefly reviewing the so-called abusive aspects of tax shelters which led Congress to enact the Tax Reform Act of 1976, the authors focus on an unintended loophole-the tax shelter proprietorship. The tax shelter proprietorship remains a viable method of reducing federal income taxes payable by high bracket taxpayers. The business mechanics and tax aspects of a sound recording proprietorship are analyzed and specific suggestions for future reforms to deal with the problem of tax shelter proprietorships are delineated.
Lewis D. Solomon and Scott G. Smith,
Detouring the Tax Reform Act of 1976: Tax Shelter Proprietorships,
32 U. Miami L. Rev.
Available at: http://repository.law.miami.edu/umlr/vol32/iss1/3