Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.
Required Textbooks:
(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0
(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2024-2025 ed.) OR Selected Federal Taxation Statutes and Regulations, 2025, Daniel J. Lathrope (West Academic 2025)
Recommended Textbooks (Optional):
(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press) (Concepts and Insights Series)
(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic) (Concise Hornbook Series)
Peroni, Robert J. 