| ARTICLES Are Separate
Liability Losses Separate for Consolidated Groups?
Don Leatherman
The A.L.I. Tax Treaty StudyA Critique and a
Modest Proposal
Philip F. Postlewaite
David S. Makarski
COMMENT
The Tax Implications of Catching Mark McGwire's
62nd Home Run Ball
NOTES
Lawsuit Proceeds Were Ordinary Income: Nahey v. Commissioner
Grant of Easement in Family Farm Triggers Section 2032A Recapture Tax:
Estate of Gibbs v. United States
Taxpayer Was Entitled to Nonrecognition of Gain Under Section 1035 on the Partial
Exchange of an Annuity: Conway v. Commissioner
Former Member of a Controlled Group Can Deduct Loss on an Intercompany Sale:
Turner Broadcasting System, Inc. v. Commissioner
Equitable Tolling Applies in Section 6532(c) in Third-Party Wrongful Levy Actions:
Becton Dickinson & Co. v. Wolckenhauer
Fair Market Value of Appreciated Property Distribution to Shareholders Determined Based
on Form of Distribution Out of Corporation, Not on Reform Received by Shareholders:
Pope & Talbot, Inc. v. Commissioner
ANNUAL REPORT
Important Developments During the Year
INDEX
Volume 52, Numbers 1, 2, 3 and 4
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