SEARCH: A Computer Program For Legal Problem Solving

This article describes a computer program called SEARCH which is designed to assist a lawyer in legal analysis. SEARCH deals with a single subject in corporate taxation, but its approach can be used for a variety of legal problems. SEARCH's subject is the attribution rules of section 318 of the Internal Revenue Code (hereinafter Code). These rules, heartily disliked by many, are seemingly complex and often both difficult and time consuming to apply.

Essentially, the attribution rules provide that a taxpayer, in certain cases, will be considered to own corporate shares that he does not actually own. Such shares are said to be attributed to taxpayer and taxpayer is said to own such shares constructively. The attribution rules apply to individuals, corporations, trusts, partnerships and estates.