Published by
Section of Taxation, American Bar Association
With the Assistance of
Georgetown
University Law CenterARTICLES
No Choice of Entity After Check-The-Box
Don W. Llewellyn and Anne O'Connell Umbrecht
Optional Partnership Inside Basis Adjustments
Martin J. McMahon Jr.
Tax Treatment of Environmental Transactions
Sheldon D. Pollack
Taxation Without Notice: Due Process and Other
Notice Shortcomings with the Partnership Audit Rules
Don R. Spellman
REPORT
Comments Regarding Retention of the Consolidated Return SRLY Rules
American Bar Association Section of Taxation Committee on Affiliated and Related
Corporations
NOTES
Section 112 Combat Pay Exclusion Does Not Apply to Separation Payment: Waterman v.
Commissioner
Restrictions on Voting Power of Majority Directors and Shareholders Reduced Voting
Power to Below Eighty Percent Under Section 1504: Alumax Inc. and Consolidated
Subsidiaries v. Commissioner
Wetland Designation Through Regulatory Change Does Not Create Involuntary Conversion
Loss: Lakewood Associates v. Commissioner
Percentage of Completion Method Allowed on Sale of Land with Long-Term Construction
Obligations; Section 7430 Costs Awarded Despite Fact Issue Was of First Impression:
Foothill Ranch Co. Partnership v. Commissioner
Valuing Perpetual Conservation Easements for Purposes of Section 170: Browning v.
Commissioner
Suspended Passive Activity Losses Not Deductible Upon a C to S Conversion: St.
Charles Investment Co. v. Commissioner |
