DOCSLIB.ORG

Real Property Like-Kind Exchanges Since 1921, the Internal Revenue

Total Page：16

File Type：pdf, Size：1020Kb

Download full-text PDF Read full-text
Real Property Like-Kind Exchanges Since 1921, the Internal Revenue Real Property Like-kind Exchanges Since 1921, the Internal Revenue Code has recognized that the exchange of one property held for investment or business use for another property of a like-kind results in no change in the economic position of the taxpayer and therefore should not result in the imposition of tax. This concept is codified today in section 1031 of the Internal Revenue Code with respect to the exchange of real and personal property, and it is one of many nonrecognition provisions in the Code that provide for deferral of gains. The Obama Administration’s fiscal year 2015 budget targets section 1031 by substantially repealing the provision with respect to real property by limiting the amount of gain that may be deferred to $1 million annually. This proposal could have a significant negative impact on the real estate sector with real implications for the broader economy. Background The original like-kind exchange rule goes all the way back to the Revenue Act of 1921 when Congress created section 202(c), which allowed investors to exchange securities and property that did not have a “readily realized market value.” This rather broad rule was eliminated in 1924 and replaced with section 112(b) in the Revenue Act of 1928, which permitted the deferral of gain on the like-kind exchange of similar property. With limited exceptions, generally related to narrowing the provision, Congress has largely left the like-kind rule unchanged since 1928.1 Section 1031 permits taxpayers to exchange assets used for investment or business purposes for other like-kind assets without the recognition of gain. This applies to both real property and personal property. The tax on such gain is deferred and in return the taxpayer carries over the basis of the original property to the new property, losing the ability to take depreciation at the higher exchange value. Gain is immediately recognized to the extent cash is received as part of the like-kind exchange, and the taxes paid on such gain serve to increase the newly-acquired property’s basis. The like-kind exchange rules permit flexibility in the exchange by giving the owner up to 180 days before or after the disposition of the original property to find replacement property, typically accomplished through the use of an intermediary. Policy Rationale The like-kind exchange rules are based on the concept that when one property is exchanged for another property there is no receipt of cash that gives the owner the ability to pay taxes on any unrealized gain. The deferral is limited and does not extend to investments that are liquid and readily convertible to cash, such as stocks, bonds, notes, securities, and inventory. The notion that section 1031 seeks to distinguish between illiquid assets, such as real estate, and readily tradable investment interests is a long-standing principle underlying the provision.2 The person who exchanges one 1 The rule was renumbered as section 1031 in the Internal Revenue Code of 1954. The Deficit Reduction Act of 1984 clarified rules governing the application of section 1031 in non-simultaneous exchanges and provided that the deferral of gain under section 1031 is not available with respect to exchanges of partnership interests. The Taxpayer Relief Act of 1997 created a special rule which provides that U.S. real property and non-U.S. real property are not property of a like-kind. Congress has also limited the availability of other tax benefits if the property was acquired in a like-kind exchange. See I.R.C. § 121(d)(10). 2 See Joint Committee on Taxation, General Explanation of the Revenue Provisions of the Deficit Reduction Act of 1984, at 245 (“Congress believed that, at least under current conditions, partnership interests typically property for another property of like-kind has not really changed his economic position; he held one property and exchanged it for another property. The taxpayer, having exchanged one property for another property of like-kind is in a nearly identical position to the holder of an asset that has appreciated or depreciated in value, but who has not yet exited the investment. Under the tax code, the mere change in value of an asset, without realization of the gain or loss, does not generally trigger a taxable event. In such situations, the proper tax treatment is to defer recognition of any gain and maintain in the new property the same basis as existed in the exchanged property. This is similar in concept to other non-recognition, tax deferral provisions in the tax code that reflect basic, broadly accepted policies about the nature of gain realization, applicable, for example, when property is exchanged for stock under section 351, when property is exchanged for an interest in a partnership under section 721, and when stock is exchanged for stock or property under section 361 pursuant to a corporate reorganization. Economic and Social Benefits of Real Property Like-Kind Exchanges The like-kind exchange rules under section 1031 are a basic tool that lubricates the smooth functioning of the real estate industry in the United States today. Allowing capital to flow more freely among investments facilitates commerce, and supports economic growth and job creation. Real estate owners use section 1031 to efficiently retain and allocate capital to its most productive uses. It enables owners to reposition portfolios, exchange peripheral assets for core assets, realign property by geography or real estate sector to improve operating efficiencies, and manage risk. By increasing the frequency of property transactions, it facilitates a more dynamic real estate sector that supports more reinvestment in real estate and a higher level of construction activity. Moreover, the ability to defer gain through a like-kind exchange leads to lower levels of leverage and debt in real estate transactions. The buyer of replacement property in a like-kind exchange is more likely to have a higher down payment because drawing out the cash proceeds from exchange sales results in immediate tax liability. According to the commercial real estate information company CoStar, from 1999 to 2005, tax- deferred exchanges represented approximately 32 percent of apartment building transactions, and 20 percent of office building transactions in the largest 15 markets. In some markets, such as San Diego and San Francisco, the majority of commercial real estate transactions in that period involved the use of like-kind exchanges. While it is quite possible that many of those transactions would have occurred without section 1031, it is also likely that many would not have occurred with the result that there would have been a less dynamic real estate market and slower economic growth. The existence of the like kind exchange rules also positively affects local government budgets since more frequent turnover of real estate generates significant property transfer and recording fees to fund government operations. Finally, section 1031 is often a critically important means of facilitating conservation real estate transactions involving important open spaces and/or significant environmentally sensitive properties that may be exchanged for other privately held like-kind property, such as adjacent farmland or ranchland. These types of transactions help to achieve the public benefit of securing the protection of environmentally significant land and open space for the future while at the same time enabling private landowners to preserve capital for expansion or diversification of existing operations, retirement, or other needs. represent investment interests similar to those items previously excluded from like-kind treatment and should therefore also be excluded from such treatment.”). - 2 - .
Load more

Recommended publications
  • Legal Status of Capital Gains
    LEGAL STATUS OF CAPITAL GAINS PREPARED BY THE STAFF OF THE JOINT COMMITTEE ON INTERNAL REVENUE TAXATION DECEMBER 4, 1959 UNITED STATES GOVERNMENT PRINTING OFFICE 48572 WASHINGTON : 1959 J0810-59 LEGAL STATUS OF CAPITAL GAINS HISTORICAL PERIOD PRIOR TO THE 16TH AMENDMENT The power of the CQngress to subject capital gains to an income tax is now fully established by decisions of the Suprenle Court. Even in our first inconle tax statute (act of 1861, 12 Stat. 292) Congress used language broad enough to warrant the taxation of "annual cap­ ital gains." This first act levied on income tax to be paid upon the "annual income" deriyecl fronl certain sources, including income "deriyed from an:r kind of property" and contained a catchall provi­ sion s,,~eeping in "income derived fronl any other source whatever" with certain exceptions having no relation to capital gains. This act was neYer put into effect and was superseded by- the act of 1862 (12 Stat. 432), ,,~hich was similar in this respect to the 1861 act except that the basis of the tax was changed fronl "annual income" to the longer nhrase "annual gains, profits, or income." It \vas not until the act of 1864 (13 Stat. 223) that income derived fronl sales of prop­ erty was specifically mentioned. This last act contained the same general definition of income referred to in the prior acts, with an additional proviso- that net profits realized by sales of real estate purchased within the year for which income is estimated, shall be chargeable as income; and losses on sales of real estate purchased within the year for which income is estimated, shall be deducted from the income of such year.
    [Show full text]
  • Table of Contents
    Table of Contents Preface ..................................................................................................... ix Introductory Notes to Tables ................................................................. xi Chapter A: Selected Economic Statistics ............................................... 1 A1. Resident Population of the United States ............................................................................3 A2. Resident Population by State ..............................................................................................4 A3. Number of Households in the United States .......................................................................6 A4. Total Population by Age Group............................................................................................7 A5. Total Population by Age Group, Percentages .......................................................................8 A6. Civilian Labor Force by Employment Status .......................................................................9 A7. Gross Domestic Product, Net National Product, and National Income ...................................................................................................10 A8. Gross Domestic Product by Component ..........................................................................11 A9. State Gross Domestic Product...........................................................................................12 A10. Selected Economic Measures, Rates of Change...............................................................14
    [Show full text]
  • International Tax Policy for the 21St Century
    NFTC1a Volume1_part2Chap1-5.qxd 12/17/01 4:23 PM Page 147 The NFTC Foreign Income Project: International Tax Policy for the 21st Century Part Two Relief of International Double Taxation NFTC1a Volume1_part2Chap1-5.qxd 12/17/01 4:23 PM Page 148 NFTC1a Volume1_part2Chap1-5.qxd 12/17/01 4:23 PM Page 149 Origins of the Foreign Tax Credit Chapter 1 Origins of the Foreign Tax Credit I. Introduction The United States’ current system for taxing international income was creat- ed during the period from 1918 through 1928.1 From the introduction of 149 the income tax (in 1913 for individuals and in 1909 for corporations) until 1918, foreign taxes were deducted in the same way as any other business expense.2 In 1918, the United States enacted the foreign tax credit,3 a unilat- eral step taken fundamentally to redress the unfairness of “double taxation” of foreign-source income. By way of contrast, until the 1940s, the United Kingdom allowed a credit only for foreign taxes paid within the British 1 For further description and analysis of this formative period of U.S. international income tax policy, see Michael J. Graetz & Michael M. O’Hear, The ‘Original Intent’ of U.S. International Taxation, 46 DUKE L.J. 1021, 1026 (1997) [hereinafter “Graetz & O’Hear”]. The material in this chapter is largely taken from this source. 2 The reasoning behind the international tax aspects of the 1913 Act is difficult to discern from the historical sources. One scholar has concluded “it is quite likely that Congress gave little or no thought to the effect of the Revenue Act of 1913 on the foreign income of U.S.
    [Show full text]
  • The Revenue Act of 1934
    March, 1935 THE REVENUE ACT OF 1934 GEORGE GRAYSON TYLER t AND JOHN P. OHL X Congress, probably inspired by the disclosures of the investigations of the Banking and Currency Committee, passed House Resolution 183, on June 9, 1933, thereby authorizing the Ways and Means Committee to in- vestigate methods of preventing the evasion and avoidance of taxes, means of simplifying the revenue laws and possible new sources of revenue. Pur- suant to this Resolution, a Subcommittee of the Committee on \Ways and Means conducted an inquiry prior to the convening of the second session of the 73d Congress. The Subcommittee filed "A Preliminary Report" ' on December 4, 1933, upon the subjects, of tax avoidance, evasion and sim- plification. In response to the Subcommittee's recommendations, the then Acting Secretary of the Treasury, Henry Morgenthau, Jr., issued a state- ment 2 differing in many important particulars from the conclusions reached by the Subcommittee. As a result of the above investigations, H. R. 7835 was introduced in the House and referred to the Committee on Ways and Means. After extensive hearings 3 the bill was reported out with amendments by the Com- 4 mittee and a report was submitted thereon. On February 21, 1934, the House passed the bill with minor committee amendments. 5 Then, having been introduced in the Senate, the bill was referred to the Finance Com- mittee, which, after further hearings,0 reported it 7 with substantial amend- ments. Further material changes were made on the floor of the Senate s before passage. Thereafter, the Conference Committee on the disagreeing votes of the two Houses made its recommendations reconciling the differ- j- Formerly assistant to Professor Roswell Magill, former assistant to the Secretary of the Treasury; member of the New York Bar.
    [Show full text]
  • Political Hot Potato: How Closing Loopholes Can Get Policymakers Cooked Stephanie Hunter Mcmahon
    Journal of Legislation Volume 37 | Issue 2 Article 1 5-1-2011 Political Hot Potato: How Closing Loopholes Can Get Policymakers Cooked Stephanie Hunter McMahon Follow this and additional works at: http://scholarship.law.nd.edu/jleg Recommended Citation McMahon, Stephanie Hunter (2011) "Political Hot Potato: How Closing Loopholes Can Get Policymakers Cooked," Journal of Legislation: Vol. 37: Iss. 2, Article 1. Available at: http://scholarship.law.nd.edu/jleg/vol37/iss2/1 This Article is brought to you for free and open access by the Journal of Legislation at NDLScholarship. It has been accepted for inclusion in Journal of Legislation by an authorized administrator of NDLScholarship. For more information, please contact [email protected]. POLITICAL HOT POTATO: HOW CLOSING LOOPHOLES CAN GET POLICYMAKERS COOKED Stephanie HunterMcMahon* ABSTRACT Loopholes in the law are weaknesses that allow the law to be circumvented Once created, they prove hard to eliminate. A case study of the evolving tax unit used in the federal income tax explores policymakers' response to loopholes. The 1913 income tax created an opportunity for wealthy married couples to shift ownership of family income between spouses, then to file separately, and, as a result, to reduce their collective taxes. In 1948, Congress closed this loophole by extending the income-splitting benefit to all married taxpayers filing jointly. Congress acted only after the federal judiciary and Treasury Department pleaded for congressional reform and, receiving none, reduced their roles policing wealthy couples' tax abuse. The other branches would no longer accept the delegated power to regulate the tax unit. By examining these developments, this article explores the impact of the separation of powers on the closing of loopholes and adds to our understandingof how the government operates.
    [Show full text]
  • Tax Reform and Capital Gains: the Aw R Against Unfari Taxes Is Far from Over Richard A
    Journal of Legislation Volume 14 | Issue 1 Article 1 1-1-1987 Tax Reform and Capital Gains: The aW r against Unfari Taxes Is Far from Over Richard A. Gephardt Michael R. Wessel Follow this and additional works at: http://scholarship.law.nd.edu/jleg Recommended Citation Gephardt, Richard A. and Wessel, Michael R. (1987) "Tax Reform and Capital Gains: The aW r against Unfari Taxes Is Far from Over," Journal of Legislation: Vol. 14: Iss. 1, Article 1. Available at: http://scholarship.law.nd.edu/jleg/vol14/iss1/1 This Article is brought to you for free and open access by the Journal of Legislation at NDLScholarship. It has been accepted for inclusion in Journal of Legislation by an authorized administrator of NDLScholarship. For more information, please contact [email protected]. TAX REFORM AND CAPITAL GAINS: THE WAR AGAINST UNFAIR TAXES IS FAR FROM OVER Richard A. Gephardt* with Michael R. Wessel** INTRODUCTION In the fall of 1986, Congress completed the process of fundamen- tally reforming the U.S. Tax Code. The House of Representatives passed a comprehensive tax reform bill late in December 1985.1 The bill underwent radical change in the Senate Finance Committee. 2 Pres- ident Reagan signed the Tax Reform Act of 19861 on October 22, 1986. The U.S. Tax Code has grown from eighty-nine pages in 19134 to thousands of pages in 1987. Additionally, the regulations and case law needed to interpret the Code require analysis of volumes of reference materials.' The Deficit Reduction Act of 19846 alone topped 1,300. pages.
    [Show full text]
  • Tax, Corporate Governance, and Norms Steven A
    Washington and Lee Law Review Volume 61 | Issue 3 Article 4 Summer 6-1-2004 Tax, Corporate Governance, and Norms Steven A. Bank Follow this and additional works at: https://scholarlycommons.law.wlu.edu/wlulr Part of the Business Organizations Law Commons, and the Tax Law Commons Recommended Citation Steven A. Bank, Tax, Corporate Governance, and Norms, 61 Wash. & Lee L. Rev. 1159 (2004), https://scholarlycommons.law.wlu.edu/wlulr/vol61/iss3/4 This Article is brought to you for free and open access by the Washington and Lee Law Review at Washington & Lee University School of Law Scholarly Commons. It has been accepted for inclusion in Washington and Lee Law Review by an authorized editor of Washington & Lee University School of Law Scholarly Commons. For more information, please contact [email protected]. Tax, Corporate Governance, and Norms Steven A. Bank* Abstract This Article examines the use offederal tax provisions to effect changes in state law corporategovernance. There is a growingacademic controversy over these provisions,fueled in part by their popularityamong legislators as a method of addressing the recent spate of corporatescandals. As a case study on the use of tax to regulate corporategovernance, this paper compares and contrasts two measures enacted during the New Deal-the enactment of the undistributedprofits tax in 1936 and the overhaul of the tax-free reorganizationprovisions in 1934-and considers why theformer was so much more controversialand less sustainablethan the latter. While some of the difference can be explained by the different political and economic circumstances surrounding each proposal, this Article argues that the divergence in the degree of opposition can be explained in part by an examination of the extent to which each provision threatened an underlying norm, or longstanding standard,of corporate behavior.
    [Show full text]
  • Tax Reform Lite the First 100 Days & the Narrow Road Ahead
    Deutsche Bank Tax Reform Lite The First 100 Days & the Narrow Road Ahead May 2017 Tom Joyce Frank Kelly Hailey Orr Mariya Getsova CIB Capital Markets Strategist Head of US Government Affairs CIB Capital Markets Strategist CIB Capital Markets Strategist The Trump Trade Markets Since the US Election Deregulation Tax Reform Infrastructure ACA Repeal S&P 500 Financials Russell 2000 US Cyclical Index S&P 500 Healthcare 1450 1900 425 Transition First 100 Days 880 1350 375 1700 830 1250 +12.6% +4.3% +15.3% +2.2% +12.1% +4.5% +2.6% +7.4% 325 1150 1500 780 08-Nov 20-Jan 29-Apr 20-Jan 08-Nov 29-Apr 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr Equity Bank Index S&P 500 DB Infrastructure Index S&P 500 Pharmaceuticals 320 2100 640 2400 260 2300 1800 590 2200 +5.8% +5.3% +20.8% +2.6% +12.8% +2.5% +1.6% +6.1% 200 2100 1500 540 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr IG Fin Credit Spreads NASDAQ Heavy Building Materials Medical Devices 140 6200 400 21500 130 5800 350 20000 120 5400 300 18500 (-9 bps) (-13 bps) +6.7% +9.2% +14.5% (-3.9%) +1.4% +13.4% 110 5000 250 17000 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr 08-Nov 20-Jan 29-Apr Deutsche Bank Source: Bloomberg.
    [Show full text]
  • U.S. Tax Imperialism in Puerto Rico
    American University Law Review Volume 65 Issue 1 Article 1 2015 U.S. Tax Imperialism in Puerto Rico Diane Lourdes Dick Seattle University, [email protected] Follow this and additional works at: https://digitalcommons.wcl.american.edu/aulr Part of the Tax Law Commons Recommended Citation Dick, Diane Lourdes (2015) "U.S. Tax Imperialism in Puerto Rico," American University Law Review: Vol. 65 : Iss. 1 , Article 1. Available at: https://digitalcommons.wcl.american.edu/aulr/vol65/iss1/1 This Article is brought to you for free and open access by the Washington College of Law Journals & Law Reviews at Digital Commons @ American University Washington College of Law. It has been accepted for inclusion in American University Law Review by an authorized editor of Digital Commons @ American University Washington College of Law. For more information, please contact [email protected]. U.S. Tax Imperialism in Puerto Rico This article is available in American University Law Review: https://digitalcommons.wcl.american.edu/aulr/vol65/ iss1/1 ARTICLES U.S. TAX IMPERIALISM IN PUERTO RICO DIANE LOURDES DICK* This Article uses historical and legal analysis to demonstrate how U.S. domination over Puerto Rico's tax and fiscal policies has been the centerpiece of a colonial system and an especially destructive form of economic imperialism. Specifically, this Article develops a novel theory of U.S. tax imperialism in Puerto Rico, chronicling the sundry ways in which the United States has used tax laws to exert economic dominance over its less developed island colony. During the colonial period, U.S. officials wrote and revised Puerto Rican tax laws to serve U.S.
    [Show full text]
  • Percentage Depletion for Oil–A Policy Issue
    INDIANA LAW JOURNAL Volume 30 SUMMER 1955 Number 4 PERCENTAGE DEPLETION FOR OIL-A POLICY ISSUE HARROP A. FREEMAN* Although it has always been recognized that lawyers were "policy makers"' and that, on the solid foundation of training in jurisprudence, principles of law, and tools of the trade, law school graduates were ex- pected to guide public or private clients in policy choices, 2 Yale Law School has more recently urged that policy formation be made the pole-star of the academic curriculum.' But, when such suggestions are made, we are forcefully reminded that we lack adequate material for such study, and. at no point is this more true than in the study of taxation.4 Yet, professors * Professor of Law, Cornell University Law School. 1. BROWN, LAWYERS, LAW SCHOOLS AND THE PUBLIC SERVICE (1948); Frey, Some Thoughts of Law Teaching and the Social Sciences, 82 U. OF PA. L. REV. 463 (1934) ; Harno, The Correlation of Law and College Subjects, 5 Am. L. SCHOOL REV. 85 (1923). 2. Brown, op. cit. supra note 1; CARDOZO, THE NATURE OF THE JUDICIAL PROCESS (1932); FRANK, COURTS ON TRIAL 240 (1949); FULLER, THE LAW IN QUEST OF ITSELF (1940); HOLMES, The Profession of the Law, The Use of Law Schools, and Law and the Courts in COLLECTED LEGAL PAPERS (1920). 3. McDoUGAL AND HABER, PROPERTY, WEALTH, LAND: ALLOCATION, PLANNING AND DEVELOPMENT (1948) ; Hale, Economics and Law in THE SOCIAL SCIENCES AND THEIR INTERRELATIONS, C. 12 (Ogburn and Goldenweiser eds. 1927); RoSTOw, A NATIONAL POLICY FOR THE OIL INDUSTRY (1948) and other publications of Yale University Seminar on National Policy.
    [Show full text]
  • James Couzens, Andrew Mellon, the “Greatest Tax Suit in the History of the World,” and Creation of the Joint Committee on Taxation and Its Staff
    NYU/UCLA TAX SYMPOSIUM THE INTERNAL REVENUE CODE AT 100 OCTOBER 19, 2012 James Couzens, Andrew Mellon, the “Greatest Tax Suit in the History of the World,” and Creation of the Joint Committee on Taxation and Its Staff George K. Yin University of Virginia School of Law September 27, 2012 DRAFT Abstract In early 1924, James Couzens was a Republican Senator from Michigan and reportedly the richest member of Congress. Andrew Mellon was beginning his fourth year as Secretary of the Treasury — a service that would eventually span 11 years under three Republican Administrations — and one of the wealthiest persons in the entire country. This article describes how a feud between these two men, an ensuing investigation led by Couzens of the Bureau of Internal Revenue (BIR) (predecessor to the modern‐day IRS), and a tax case against Couzens that was described as the “greatest tax suit in the history of the world,” helped lead to creation of the U.S. Joint Committee on Taxation (JCT) and its staff. The events — filled with political intrigue, backstabbing (real or imagined), and unintended consequences — antagonized Congress’s relationship with the executive branch, but improved cooperation between the House and Senate, and both were instrumental in the JCT’s creation. The story also provides insight on the unique role the JCT has played in Congress for over 85 years. Finally, the article explains how creation of the JCT became entangled with two of the most contentious tax issues of the day — the publicity of tax return information and the depletion allowance for oil and gas production — and played a role in changing the law in both areas.
    [Show full text]
  • The Historical Origins of the Debt-Equity Distinction
    The Peter A. Allard School of Law Allard Research Commons Faculty Publications Allard Faculty Publications 2015 The Historical Origins of the Debt-Equity Distinction Camden Hutchison Allard School of Law at the University of British Columbia, [email protected] Follow this and additional works at: https://commons.allard.ubc.ca/fac_pubs Part of the Banking and Finance Law Commons, Legal History Commons, and the Tax Law Commons Citation Details Camden Hutchison, "The Historical Origins of the Debt-Equity Distinction" (2015) 18:3 Fla Tax Rev 95. This Article is brought to you for free and open access by the Allard Faculty Publications at Allard Research Commons. It has been accepted for inclusion in Faculty Publications by an authorized administrator of Allard Research Commons. FLORIDA TAX REVIEW Volume 18 2015 Number 3 ARTICLE THE HISTORICAL ORIGINS OF THE DEBT-EQUITY DISTINCTION Camden Hutchison 95 i FLORIDA TAX REVIEW Volume 18 2015 Number 3 The Florida Tax Review is a publication of the Graduate Tax Program of the University of Florida Levin College of Law. Each volume consists of ten issues. The subscription rate, payable in advance, is $125.00 per volume in the United States and $145.00 per volume elsewhere. If a subscription is to be discontinued at expiration, notice to that effect should be sent; otherwise, it will be automatically renewed. Subscriptions and changes of address should be sent to: Florida Tax Review, University of Florida Levin College of Law, Post Office Box 117634, Gainesville, Florida 32611-7627. Requests for back issues should be sent to: William S.
    [Show full text]