Finding Aid for the Martin Atlas Papers (Coll. 23) MSS.023

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Transcription:

Finding Aid for the Martin Atlas Papers (Coll. 23) MSS.023 Finding aid prepared by Laura Bedard in 2003, updated by Hannah Miller in 2014 This finding aid was produced using the Archivists' Toolkit March 31, 2014 Manuscripts Collection Georgetown University Law Library 111 G. Street NW Washington, D.C., 20001 202-662-9133 specl@law.georgetown.edu

Table of Contents Summary Information... 3 Biography... 4 Description... 4 Administrative Information...4 Controlled Access Headings...5 Collection Inventory... 6 - Page 2 -

Summary Information Repository Manuscripts Collection Creator Atlas, Martin Title Martin Atlas Papers Date [bulk] Bulk, 1937-1949 Date [inclusive] 1929-1966 Extent 3.6 Linear feet (9 archival boxes) Language English Preferred Citation Martin Atlas Papers. Georgetown University Law Library Manuscripts Collection. - Page 3 -

Biography Martin Atlas was a well known tax lawyer. He worked at the Cafritz Foundation from 1948-1993, serving as its president at one point. He received his law degree from George Washington University in 1945. He was also an attorney-economist at the United States Department of the Treasury from 1936-1947. He was also a consultant to the Secretary for the Interior from 1950-1951. He has written many books on tax law, including "Handbook of Tax Techniques". He was also a professorial lecturer at American University, the University of Hawaii at Honolulu, the New York Institute on Federal Taxation, the Wisconsin Tax Institute, and the Tulane Tax Institute. Description The collection contains personal memoranda of Martin Atlas, Federal Tax legislation proposals, and Tax studies. Many of the materials are originals, photocopies and government reports. Administrative Information Publication Information Manuscripts Collection Rights All rights reserved by Georgetown University Law Library unless otherwise noted. Processing Information note These papers have been re-boxed in lignin-free letter size boxes, and numbered 1-9. They remain loosely in their original order. This collection is partially processed in that all staples and paper clips still need to be removed and fragile paper preserved. Oversized materials need to be properly stored in a larger box. - Page 4 -

Controlled Access Headings Corporate Name(s) United States. Department of the Treasury. - Page 5 -

Collection Inventory Box Folder Estate & Gift Tax-: Loose MSS Materials taken out of Book I: Estate and Gift Tax Data. Aug. 1943-Dec. 1944 1 1 Estate & Gift Tax: Book I: Estate and Gift Tax Data: August. 1943- Dec. 1944; Table of Contents and Tabs 76-66 1 1.1 Estate & Gift Tax: Book I: Estate and Gift Tax Data: Aug. 1943- Dec. 1944; Tabs 65-50 1 1.2 Estate & Gift Tax: Book I: Estate and Gift Tax Data; Aug. 1943- Dec. 1944; Tabs 49-29 1 1.3 Estate & Gift Tax: Book I Estate and Gift Tax Data; Aug. 1943- Dec. 1944; Tabs 28-15 1 1.4 Estate & Gift Tax: Book I Estate and Gift Tax Data: Aug. 1943- Dec. 1944; Tabs 14-1 1 1.5 Capital Gains Folder [Research on Excess-Profits Tax; Tax Avoidance; Personal Finance Companies; and Taxation of Capital Gains; Comparison of Revenue Acts from 1941 and 1942] 1 2 Tax Memos: Binder (Memos): September 1940-September 1941 1 3 - Page 6 -

Law Review Articles: Law Review and Articles Folder (4 Memos by Martin Atlas?1946) 2 4 Speeches Folder 2 5 Misc. Pamphlets: Accordion Folder I 2 6 Real Estate: Accordion Folder I: Subfolder A (Tax Treatment of Gains and Losses from Sales of Real Estate) 2 6.1 Tax Analysis: Accordion Folder I: Subfolder B (MSS) 2 6.2 Tax Analysis: Accordion Folder I: Subfolder C (MSS) 2 6.3 Amortization of Bond Premium on Discount: Accordion Folder I: Subfolder D?Amortization of Bond Premium on Discount? 2 6.4 Personal Memos and Materials [Articles and Draft Tax Papers for Publication]: Accordion Folder I: Subfolder E (Loose MSS Materials) Date-[1947-49] 2 6.5 Personal Memos and Materials: Accordion Folder I: Subfolder F (MSS): For Mr. Atlas 9-5-50 to September 5, 1950 [Problems in Buying and Selling Real Property; Tax Factors in Original Organization; Buying Stock to Get Assets or Caveat Emptor and Venditor; Contemplation of Death Today 2 6.6 Memos: Binder (Memos): June 1, 1937 [Provisions of the Internal Revenue Code relating to the Taxation of Interest on Tax-Exempt 2 7 - Page 7 -

Securitites Under the Excess-Profits Tax; Analysis of the Capital Stock Tax as a Method of Taxing Deficit Corporations, 2/10/45; Revenue Effects of Revising the 80-percent Limitation, 3/19/45; The Effect of the War on the Smaller Corporation, 11/1/43; Draft-Analysis of data relating to corporate profits for the years 1939 to 1942 from the Department of Commerce sample? Draft- Procedure for estimating the volume of business done by all cooperative, 3/20/45 Excise Tax: Binder: Excise Taxes Considered but not Proposed (Memos and MSS) Oct. 1943-Oct. 1944 2 8 Misc. Docs.: Binder: Loose MSS, Reports 2 8.1 Misc. Docs.: Binder: 12/30/42-6/24/42 (MSS) December 30, 1942- June 24, 1942 [Supplement to Public Policy Digest: The Inflation Problem, October 1942; Multiples Letters, Memos and other correspondence;? Controversies over Methods of War Taxation, 9/21/42] 3 9 Misc. Docs.: Binder: 7/30/42-4/1/42 (MSS) April 1, 1942- July 30, 1942 [Memos and Reports] 3 9.1 Clifford Administrative Solutions: Untitled Book (MSS): Divider I: The Clifford Problem: An Analysis of the Cases and a Proposed Administrative Solution 3 10 Family Partnerships: Untitled Book (MSS): Divider II: Memo to Mr. Wales from Mr. Graves 0/1/44 Taxation of Income of Family Partnerships- "Sept. 1, 1944" 3 10.1 Estate and Gift Tax: Book II: Estate and Gift Tax Data (MSS) January 1945 3 11 - Page 8 -

Estate and Gift Tax: Book II: Estate and Gift Tax Data (MSS) January 1945-tabs 10-1 3 11.1 Misc. Docs. Memoranda Prepared by Martin Atlas: 1948 (Tabs 60-31) [Closing Agreements and Memoranda on taxes] 3 12 Misc. Docs.: Memoranda Prepared by Martin Atlas: 1948 (tabs 30-1) [Closing Agreements and Memoranda on taxes] 3 12.1 Misc. Docs.: Green Loose MSS [Proposed Study of the Undistributed Profits Tax Tables and Research] 3 13 Misc. Docs.: Green Loose MSS [Proposed Study of the Undistributed Profits Tax Tables and Research] 3 13.1 Misc. Docs.: Green Loose MSS [Proposed Study of the Undistributed Profits Tax Tables and Research] 3 13.2 Misc. Docs.: Binder: July 1936-April 1937 (April 30, 1937- April 3, 1937) [Letters, Memos, and Reports] 4 14 Misc. Docs.: Binder: July 1936- April 1937 (March 2, 1937- Dec. 19, 1936)[Letters, Memos, and Reports] 4 14.1 Misc. Docs.: Binder: July 1936- April 1937 (December 15, 1936- Aug. 28, 1936) 4 14.2 Misc. Docs. Loose MSS (1946-47) 4 15 - Page 9 -

Misc. Docs. Loose MSS (1945-46) 4 15.1 Federal Retail Sales Tax; Comparative Tax Law-Binder: Considerations "Respecting a Federal Retail Sales Tax: Part C Canadian Federal Sales Tax, ""British Purchase Tax, Australian Wholesale Sales Tax (tabs a-c)" 4 16 Federal Retail Sales Tax; Comparative Tax Law- Binder: Considerations "Respecting a Federal Retail Sales Tax: Part C Canadian Federal Sales Tax, ""British Purchase Tax, Australian Wholesale Sales Tax (tab d)" 4 16.1 Misc. Docs. Binder: April to July 1939 (MSS) April 1939-July 1939 4 17 Letters-Binder: Jan.- Sept. 1938 (MSS) Jan. 1938-Sept. 1938 4 18 Letters-Binder: Jan.-Sept. 1938 (MSS) Jan. 1938- Sept. 1938 4 18.1 Taxpayer Opinion; Income Tax; Capital Stock; Excess Profits-Binder: Report of Taxpayers' Opinion (sections 1 & 2) 4 19 Taxpayer Opinion; Estate and Gift Tax; Social Security Tax; Excise Tax- Binder: Report of Taxpayers' Opinion (sections 3-6) 4 19.1 Tax Relief; Family Tax; Comparative Tax Law; House Bills-Binder: January-September 1943 Reports 5 20 Proposed Tax Legislation, Comparative Tax Law-Binder: January-Sept. 1943 Reports 5 20.1 - Page 10 -

Proposed Tax Legislation- Binder: January- September 1943 Reports 5 20.2 Proposed Tax Legislation; Victory Tax; Ruml Plan- Binder: January- September 1943 Reports 5 20.3 Proposed Tax Legislation-Binder: January-September 1943 Reports 5 20.4 Proposed Tax Legislation, Comparative Tax Law-Binder: January- September 1943 Reports 5 20.5 Estate and Gift Tax-Binder: Estate and Gift Tax Reports 5 21 Estate and Gift Tax-Binder: Estate and Gift Tax Reports 5 21.1 Misc. Docs.: Memoranda Prepared by Martin Atlas 1947: Book I January to Jun-47 5 22 Misc. Docs. Memoranda Prepared by Martin Atlas 1947: Book I January to Jun-47 5 22.1 Bank Taxes. Problems in the Income Taxation of Banks 5 23 Misc. Reports, Letters, and Memos- Miscellaneous Accordion Folder [From 1937 to 1946] 6 24 Misc. Reports and Memos-Miscellaneous Accordion Folder [From 1941 to 1948; Revenue Revision, 1947-48: Reports of the Special Tax Study Committee to the Committee on Ways and Means House of 6 24.1 - Page 11 -

Representatives; British and American Plans for International Currency Stabilization by J.H. Riddle] Tax Treatment of Savings. Miscellaneous Accordion Folder [Preferential Tax Treatment of Selected Categories of Savings, Report by the Division of Tax Research, Treasury Department, June 3, 1948] 6 24.2 Proposed Tax Legislation. Statement on Tax Revision 1937 (For the Ways and Means Subcommittee on Taxation sections I, II, III, IV, and V tentative draft) 6 25 National Tax Analysis. Statement on Tax Revision 1937 (Miscellaneous Loose Items taken from this document) 1929-1942 6 25.1 Proposed Tax Legislation. Proposed Constitutional Amendment to Prohibit "Federal Tax Rates Exceeding 25% (May 31, 1944)" 6 26 Binder: July 1943-Feb. 24, 1944 [Binder of Reports, Letters, and Memos] 6 27 Binder: July 1943- Feb. 24 1944 [Binder of Reports, Letters, and Memos] 6 27.1 Misc. Docs. Loose MSS Materials Taken from Binder Jun.- Nov. 1943 [February 1945 Letter to Mr. McGlinchey; 1948 Memo to Mr. DeWind; Report on Averaging and Loss Carry-Over in Income Taxation] 6 28 Misc. Docs. Binder: June- November 1943 [Binder of Reports, Letters, and Memos from 1943] 6 29 Misc. Docs. Binder: June-November 1943 [Binder of Reports, Letters, and Memos from 1943] 6 29.1 - Page 12 -

Federal Tax History. Federal Tax Chronology: 1928-1937 Division of "Research and Statistics, September 2, 1937" 7 30 Tax Policy. Tax Revision Studies, 1937. Volume I: General Statement, "Revenue Estimates, Summaries and Recommendations. Division of Research "and Statistics. August 31, 1937 7 31 Income, Capital Stock, Excess-profits taxes. Tax Revision Studies, 1937. "Volume II: Income, Capital Stock, and Excess-Profits Taxes, Division of "Research and Statistics, August 31, 1937 7 32 Capital Gains Tax. Tax Revision Studies, 1937. Volume III: Capital Gains Tax, "Division of Research and Statistics, August 31, 1937 7 33 Undistributed Profits. Tax Revision Studies, 1937. Volume IV: Undistributed "Profits Tax, Division of Research and Statistics, August 31, 1937 7 34 Estate and Gift Taxes. Tax Revision Studies, 1937. Volume V: Estate and Gift "Taxes Division of Research and Statistics, August 31, 1937 7 35 Binder: August- December 1939 [Binder of Reports, Letters, and Memos from 1939] 7 36 Personal Income Tax. The Personal Income Tax and the Crediting Device. Research report prepared for the Interstate Commission on Conflict Taxation 7 37 - Page 13 -

Surplus Taxes. File: Administration of Section 102 of the Code Relating to Improperly Accumulated Surplus. 7 38 Personal Materials of M. Atlas. Loose MSS Materials. 1946-1947 8 39 Comparative Tax Law. U.S. Plan U.K. and Canada 1936-1944 8 40 Misc. Docs. Analysis of Reports Atlas [Atlas Comments on Section 124A Draft; Atlas Letter to Mr. Zucker; Income Taxation, 1941 (For National Year Book); Treatment of Capital Gains and Losses Under the British Income Tax; Analysis of Interim Report of the Surplus War Property Subcommittee of the Senate Special Committee to Study Problems of American Small Business, Disposal of Surplus Consumer Goods by the Treasury Department, February 27, 1945; Analysis of the Drug Industry with Particular Reference to the Problems of Surplus Drugs; Analysis of the VE 10 Report; Analysis of Additional Report of the Special Committee Investigating the National Defense Program, Disposal of Surpluses Other than Industrial Plants, March 23, 1945] 8 41 Misc. Docs. Unlabeled Manila Folder: Loose MSS Items. 1941-1946 [Various Reports and Memoranda] 8 42 Tax Legislation. Checklist of Legislative Matters in Connection with the 1946 "Tax Bill. February 1, 1946" 8 43 Tax Planning, Construction. Tax Planning for the Construction Industry "(Annotated) by Martin Atlas, 1962 8 44 Real Estate Tax. Tax Aspects of Real Estate Transactions by Martin Atlas. 1955 8 45 - Page 14 -

Real Estate Tax. Tax Aspects of Real Estate Transactions (Revised Edition, Annotated National Association of Home Builders Edition) by Martin Atlas. 1959 8 46 Closing Agreements. Memoranda Prepared by Martin Atlas, 1946: Table of Contents and Closing Agreements (Tabs 1-20) 8 47 Powers of Appointment. Memoranda Prepared by Martin Atlas, 1946: Powers of Appointment (Tabs 21-35) 8 47.1 Recapitalization (Tabs 36-42) Memoranda Prepared by Martin Atlas, 1946 8 47.2 Misc. Docs. Memoranda Prepared by Martin Atlas, 1946: Miscellaneous (Tabs "43-51)[Martin Atlas Resume, Letters, and Reports] 8 47.3 Govt. Pensions. Memoranda Prepared by Martin Atlas, 1946: Government Pensions (Tabs 52-63) 8 47.4 Stock Options. Memoranda Prepared by Martin Atlas, 1946: Stock Options (Tabs 64-73) 8 47.5 Private Relief; Proposed Legislation. Memoranda Prepared by Martin Atlas, 1946: Private Relief Bills (Tabs 74-89) 8 47.6 Misc. Topics. Memoranda Prepared by Martin Atlas, 1946. [Memos and Letters] 8 47.7 Misc. Docs. Binder: Sept.-Dec. 1938, part 1. [Memos, Letters, and Reports] 9 48 - Page 15 -

Misc. Docs. Binder: Sept. Dec. 1938, part 2. [Letters, Statement By the President in Summation of the 1939 Budget, Valuation of Inventory Memo] 9 48.1 Misc. Docs. Binder: MSS Materials: April 26, 1937- Dec. 31, 1937, part 1. [Memos, Letters, and Reports] 9 49 Misc. Docs. Binder: MSS Materials: April 26, 1937- Dec. 31, 1937, part 2. [Tax Division Studies 1937 Excise Taxes] 9 49.1 Misc. Docs. Binder: MSS Materials: April 26, 1937- Dec. 31, 1937, part 3. [Correspondence on Netherlands Legislation; Memos; Letters; and Reports] 9 49.2 Misc. Docs. Binder: MSS Materials: 1931-1940, part 1 9 50 Misc. Docs. Binder: MSS Materials: 1931-1940, part 2 9 50.1 Misc. Docs. Binder: MSS Materials: 1931-1940, part 3 [Letters and Report on Last-in-first-out inventory method] 9 50.2 Inflation- Treasury Record on Inflation by Martin Atlas, part 1 9 51 Inflation- Treasury Record on Inflation by Martin Atlas, part 2 9 51.1 Misc. Docs. Binder: MSS Materials: September 4, 1941-March 27, 1942, part 1 [Monthly Report on Projects in the Division of Tax Research, February, 1942; Data on Transactions on London and Toronto Stock Exchnages; Hearings: Revenue Division of 1942, Committee on Ways and 9 52 - Page 16 -

Means, March 19, 1942; Taxation of Capital Gains in Foreign Countries; Morris L. Ernst's Proposal to Encourage Annual Salary Contracts Through Tax Incentives; and other Memos] Misc. Docs. Binder: MSS Materials: September 4, 1941-March 27, 1942, part 2 [Memos; Letters; and Problems in the Income and Excess Profits Taxation of Banks 9 52.1 Misc. Docs. Binder: MSS Materials: September 4, 1941-March 27, 1942, part 3 [Letters, Memos, and Reports] 9 52.2 Misc. Docs. Binder: January, 1940 part 1 [Statement on Fluctuation in Business Profits; Treatment of Domestic Corporations with None of Their Income from Sources Within the United States Under the Excess Profits Tax; Memos; and Letters] 9 53 Misc. Docs. Binder: January, 1940 part 2 [Letters and Memos] 9 53.1 Misc. Docs. Binder: January, 1940 part 3 [Letters and Memos] 9 53.2 - Page 17 -