Walter D. Schwidetzky

University of Baltimore - School of Law

Professor

1420 N. Charles Street

Baltimore, MD 21218

United States

SCHOLARLY PAPERS

15

DOWNLOADS
Rank 22,963

SSRN RANKINGS

Top 22,963

in Total Papers Downloads

2,812

SSRN CITATIONS

1

CROSSREF CITATIONS

3

Scholarly Papers (15)

1.

Integrating Subchapters K and S-Just Do it

Tax Lawyer, Vol. 62, No. 3, p. 749, 2009, University of Baltimore School of Law Legal Studies Research Paper No. 2010-04
Number of pages: 75 Posted: 01 Oct 2009 Last Revised: 03 Mar 2010
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 1,034 (27,510)
Citation 2

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business entities, Subchaper K, Subchapter S, partnerships, S corporations, taxation, LLC's, limited liability companies, closely held businesses, H.R. 4137

2.

The Partnership Allocation Rules of Section 704(b): To Be or Not to Be

Virginia Tax Review, Vol. 17, No. 4, 1998
Number of pages: 52 Posted: 16 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 894 (33,792)

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partnership allocation regulations, substantial economic effect rules, nonrecourse deductions rules, Crane v. Commissioner, taxation

3.

Family Limited Partnerships: The Beat Goes On

Tax Lawyer, Vol. 60, p. 277, 2007
Number of pages: 65 Posted: 03 Sep 2008 Last Revised: 27 Jan 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 193 (199,602)

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family limitied liability entities, FLLEs, limited partnerships, limited liability companies, estate taxes, gift taxes, Internal Revenue Code, taxation

4.

A Comparison of Corporate Taxation in the United States and Germany: Different Ways Up the Mountain

Georgia Journal of International and Comparative Law, Vol. 28, P. 217, 2000
Number of pages: 31 Posted: 17 Oct 2000 Last Revised: 13 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 142 (258,801)

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United States, Germany, taxation, corporations, financial accounting rules, taxation of dividends, capital gains, capital losses, liquidations, reorganizations

5.

Options to Acquire Partnership Interests: Can the Tax Law Keep Pace?

Journal Taxation of Investments, Vol. 20, No. 2, 2003
Number of pages: 23 Posted: 16 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 107 (318,546)

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partnerships, options, federal tax treatment, IRS, Internal Revenue Service, services option, limited liability companies

6.

Partnership Taxation: Restructuring Partnership Debt - Life is Change

Virginia Tax Review, Vol. 11, No. 3, 1992
Number of pages: 56 Posted: 22 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 89 (358,776)

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partnership debt, partnership taxation, U.S. v. Kirby Lumber, Bankruptcy Tax Act of 1980, COD, partnership insolvency

7.

Is it Time to Give the S Corporation a Proper Burial?

Virginia Tax Review, Vol. 15, No. 4, 1996
Number of pages: 61 Posted: 18 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 85 (369,172)

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S Corporations, small businesses, limited liability company, LLC, limited liability partnership, LLP

8.

Last-Gasp Estate Planning: The Formation of Family Limited Liability Entities Shortly Before Death

Virginia Tax Review, Vol. 21, No. 1, 2001
Number of pages: 41 Posted: 16 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 80 (382,667)

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family limited partnerships, estate tax planning, LLCs, limited liability companies, family limited liability entity, FLLE, Strangi

9.

The New Activity Regulations Under Section 469: Into the Abyss

Virginia Tax Review, Vol. 9, No. 3, 1990
Number of pages: 71 Posted: 24 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 50 (484,771)

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Tax Reform Act of 1986, passive loss rules, passive income, legislative history, taxation, IRS, Internal Revenue Service

10.

Proposed Regulations on Noncompensatory Options: A Light at the End of the Tunnel

Journal of Taxation of Investments, Vol. 21, No. 2, Winter 2004
Number of pages: 32 Posted: 29 Jun 2004 Last Revised: 13 Apr 2009
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 36 (549,638)

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partnerships, noncompensatory options, services options, regulations, taxation

11.

Hyperlexis and the Loophole

Oklahoma Law Review, Vol. 49, No. 3, Fall 1996, pp. 403-424
Number of pages: 22 Posted: 01 Oct 2014
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 33 (565,714)
Citation 1

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hyperlexis, Congress, tax law, Internal Revenue Code, partnership taxation, subchapter K, loopholes, value added tax

12.

Complexity Cubed: Partnerships, Interest, and the Proposed Regulations

Tax Notes Federal, November 18, 2019, University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 98 Posted: 12 Feb 2020
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 23 (627,764)

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business interest expenses, section 163(j), partnerships

13.

Estate Planning: Hyperlexis and the Annual Exclusion Rule

Suffolk University Law Review, Vol. 32, No. 2, 1998, pp. 211-232
Number of pages: 22 Posted: 01 Oct 2014
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 20 (648,936)

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Internal Revenue Code, I.R.C. ยง 2503(b), gift tax, gifts, taxpayers, simplification, hyperlexis, Bayless Manning, federal legislatures, state legislatures, complexity

14.

In Defense of the PIP Regulations

72 The Tax Lawyer 519 (2019), University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 32 Posted: 12 Feb 2020
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 19 (656,119)

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Fair market value; Case law; Taxation; Stockholders; Partnership agreements; Partnership interest; Tax basis; Limited partnerships; S corporations; Pass through entities

15.

Temporary and Proposed Section 752 Regulations: Progress or Regress?

35 Journal of Taxation of Investments 3 (2017), University of Baltimore School of Law Legal Studies Research Paper Forthcoming
Number of pages: 39 Posted: 12 Feb 2020
Walter D. Schwidetzky
University of Baltimore - School of Law
Downloads 7 (748,342)

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bottom-dollar guarantee, economic risk of loss, recourse debt, commercially reasonable, anti-abuse regulation