Pittsburgh Tax Review
Wayne M. Gazur, Abandoning Principles: Qualified Tuition Programs and Wealth Transfer Taxation Doctrine, 2 Pitt. Tax. Rev. 1 (2004), available at https://scholar.law.colorado.edu/articles/486.
In 1996 Congress gave its imprimatur to a modest qualified tuition program provision. Over the course of the next five years the provision was expanded, providing additional wealth transfer taxation and income taxation benefits. This essay proposes that unless limited, such benefits are inconsistent with established taxation principles and also have the potential to undermine the integrity of the wealth transfer tax structure and the progressive nature of the income tax.
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