Crane Material Study [Background and History of Crane v. Commissioner of the Revenue, 331 U.S. 1 (1947), 2001

George K. Yin, Emeritus Professor of Law at the University of Virginia School of Law donated this collection that relates to three important subjects: ALI (American Law Institute) Reporters’ Study; Subchapter C Study (1983-1989) and Crane v. Commissioner of the Revenue, 331 U.S. 1 (1947).

ALI (American Law Institute) Reporters’ Study: These files relate to George Yin’s service as ALI Reporter on a federal income tax project entitled “Taxation of Private Business Enterprises.” In professor Yin’s words: “The project developed and described proposed changes to the taxation of private U.S. businesses — essentially all businesses other than large, public corporations. The work implicates law currently found in subchapters C, K, and S of the Internal Revenue Code. The work was carried out between 1994 and 1999 in conjunction with David Shakow.

There are two types of material included in the folders. The bulk of the material consists of correspondence, memos, emails, and other material—organized in reverse chronological order—discussing many of the issues presented in the bound volumes. Most of the emails and memos are between my co-reporter and me and most of the correspondence is with the project’s consultants, members of the ALI tax program committee and tax advisory group, and other interested professionals. We presented our interim findings at a series of meetings involving these groups and spoke about some of the work in other public settings. There are four “chron” folders containing this material: 1993-95 (first document is Dec. 8, 1993), 1996, 1997, and 1998-2001 (last document is Jan., 2001). I have culled out and discarded material involving purely administrative matters and not gone through my electronic files to supplement the emails and other material in the folders. But when I worked on the project, I tended to print out and keep hard copies of most important material.

The other material, all in one folder, includes miscellaneous (mostly handwritten) notes I made and retained during the course of the project. Most notes are undated and are not set out in any particular order."

Subchapter C Study (1983-1989), relates to the taxation of corporations and corporate transactions. Contains memoranda, correspondence and documents related to the proposed revision to Subchapter V of the Internal Revenue Code that were considered by the US Senate Finance Committee in 1985. Work on the project began in 1983 and was initially led by Andre LeDuc, tax counsel for the committee. George Yin joined the staff in mid-1983, as tax counsel, and took responsibility of the project when LeDuc left in the Fall of that year and continued to be responsible for the project until he left in 1985.

Crane Material Study [Background and history of Crane v. Commissioner of the Revenue, 331 U.S. 1 (1947)