Published by
Section of Taxation, American Bar Association
With the Assistance of
Georgetown
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ARTICLES
Form, Substance and Directionality in
Subchapter C
Lewis R. Steinberg
Beyond the IRS Restructuring and Reform
Act 1998: Perceived Abuses of the Treasury Deparment's Rulemaking Authority
Naftali Z. Dembitzer
Size Matters: Section 367(a) and
Acquisitions of U.S. Corporations by Foreign Corporations
Robert J. Staffaroni
TESTIMONY
Testimony of Stefan F. Tucker on Behalf of the Section of Taxation, American Bar
Association. Before the Subcommittee on Oversight
of the U.S. House of Representatives on the the Subject of Revenue Provisions in the
President's FY200 Budget, March 10, 1999
Testimony of Stefan F. Tucker, Chair, Section of Taxation, Before
the ABA Commission on Multidisciplinary Practice, Los Angeles, California, February 4,
1999
NOTES
Portion of Settlement in Personal Injury Case Allocated to Taxable Prejudgment
Interest: Rozpad v. Commissioner
Valuing Future Lottery Winnings for Estate Tax Purposes:
Estate of Shackleford v. United States
QTIP Election Valid Where the Will Allowed Reduction in the Surviving Spouse's
Interest: Estate of Rinaldi v. Commissioner
State Law Disclaimer Did Not Prevent the Attachment of Federal Tax Liens to Inherited
Property: Drye Family 1995 Trust v. United States
Section 104 Does Not Apply to Disability Payment Made Pursuant to Labor Agreements: Wallace
v. United States
Inventory Shrinkage Estimates Are Not Prohibited by Treasury Regulation Section
1.471-2(d): Wal-Mart Stores v. Commissioner and Dayton Hudson v.
Commissioner. |