Taxes the Tax Magazine 1991: Vol 69 Index

9 Pages·1991·2.8 MB·English

1991 Annual Indexes
Subject Index
Authored and unauthored feature articles appearing in Taxes during 1991 are indexed below under at
least one general subject heading. In some instances, a feature article is indexed under more than one
general subject heading.
Accounting immunized testimony and subsequent tax prosecutions.
Gifts of inventory to charity. Oct., p.588. Feb., p.67.
Interest accrual on an uncontested tax deficiency. Oct., Debt
p.620. Transfer of indebtedness. Dec., p.939.
Bankruptcy Deductions and Exclusions
Federal income tax consequences of restructuring debt of Amortizing term interests in partnership property and
failing corporations after the Revenue Reconciliation interests, April, p.244.
Act of 1990, April, p.214. Deductibility of takeover costs after National Starch. Jan.,
Loss carryovers in corporate bankruptcy reorganizations p.48.
under Prop. Reg. § 1.269-3(d), April, p.229. Economic performance. Jan., p.60.
Payment of delinquent payroll taxes. Jan., p.31. Payments in advance of performance. Dec., p.798.
Corporations Self-employed individuals, reducing net earnings. June,
Classification of domestic and foreign entities indirectly p.372.
owned by a single interest. Nov., p.659. Tax treatment of Superfund cleanups. Nov., p.682.
Computation of the corporate marginal tax rate. Oct., Discovery Rules
p.625. Bringing tax cases in District Court. March, p. 167.
Deductibility of takeover costs after National Starch. Jan., Tax court discovery rules—the Westreco case. Jan., p.19.
p.48 Tax court discovery rules v. IRS summons authority—the
Disposition of a subsidiary by a consolidated group. Jan., Ash case. Nov.,p.690.
p.56; March, p.139 The interplay between formai and informal IRS information
Federal income tax consequences of restructuring debt of gathering. Feb., p.83.
failing corporations after the Revenue Reconciliation The IRS summons as a Tax Court discovery tool. Aug.,
Act of 1990. April, p.214. p.501.
Gifts of inventory to charity. Oct., p.588.
Dividends
Incorporating intangible assets into the transfer price
Compensation or dividend distributions? Sept., p.546.
formula. Feb., p. 100.
Information reporting, record maintenance, and transfer Divorce
pricing. March, p.172. Section 1041—No recognition of gain or loss. July, p.438.
Interest accrual on an uncontested tax deficiency. Oct., Transfer of property between spouses or former spouses.
p.620. Jan., p.37; Jan., p. 41.
Loss carryovers in corporate bankruptcy reorganizations Employee Plans
under Prop. Reg. § 1.269-3(d). April, p.229. Spousal rollovers of retirement plan distributions. Aug.,
Notional principal contract income. June, p.343. p.513.
Proposed consolidated return regulations. July, p. 395. Employment Discrimination
Reorganization after General Utilities. Dec., p.882. Taxation of employment discrimination awards. Oct.,
RJR Nabisco “‘high yieid”’ securities exchange. Feb., p.74. p.608.
RJR Nabisco securities: Exchange of debentures for cash Environmental Issues ‘i
and common stock. April, p. 251.
Tax treatment of Superfund cleanups. Nov., p.682.
Salomon Phibro crude oil trust. July, p.416.
Estate and Retirement Planning
Spin-Offs: Divesting after General Utilities. Dec., p.€89.
Asset accumulation, retention and protection: Prelude to
Tax treatment of Superfund cleanups. Nov., p.682.
transmission. Dec., p.7 17.
The single entity theory of the consolidated Section 382
Charitable remainder trust. Feb., p. 106.
Regs. Dec., p.915.
Estate freezes. Jan., p.3; March, p.151.
The USX tracking stock spin-off.June, p.383.
Spousal rollovers of retirement pian distributions. Aug.,
Transfers between United States persons and foreign
p.513.
corporations pursuant to proposed Section 367 Regs.
Nov., p.671. Exempt Organizations
Valuation of closely held stock for transfer tax purposes: Gifts of inventory to charity. Oct., p.588.
Minority discounts for intrafamily transfers in family- Gifts of tangible personal property. Nov., p.706.
controlled corporations. May, p.309. Lobbying by exempt organizations. July, p.422.
Criminal Tax Finance
1082 TAXES /December 1991
1991 Annual Indexes
Subject Index
Authored and unauthored feature articles appearing in Taxes during 1991 are indexed below under at
least one general subject heading. In some instances, a feature article is indexed under more than one
general subject heading.
Accounting immunized testimony and subsequent tax prosecutions.
Gifts of inventory to charity. Oct., p.588. Feb., p.67.
Interest accrual on an uncontested tax deficiency. Oct., Debt
p.620. Transfer of indebtedness. Dec., p.939.
Bankruptcy Deductions and Exclusions
Federal income tax consequences of restructuring debt of Amortizing term interests in partnership property and
failing corporations after the Revenue Reconciliation interests, April, p.244.
Act of 1990, April, p.214. Deductibility of takeover costs after National Starch. Jan.,
Loss carryovers in corporate bankruptcy reorganizations p.48.
under Prop. Reg. § 1.269-3(d), April, p.229. Economic performance. Jan., p.60.
Payment of delinquent payroll taxes. Jan., p.31. Payments in advance of performance. Dec., p.798.
Corporations Self-employed individuals, reducing net earnings. June,
Classification of domestic and foreign entities indirectly p.372.
owned by a single interest. Nov., p.659. Tax treatment of Superfund cleanups. Nov., p.682.
Computation of the corporate marginal tax rate. Oct., Discovery Rules
p.625. Bringing tax cases in District Court. March, p. 167.
Deductibility of takeover costs after National Starch. Jan., Tax court discovery rules—the Westreco case. Jan., p.19.
p.48 Tax court discovery rules v. IRS summons authority—the
Disposition of a subsidiary by a consolidated group. Jan., Ash case. Nov.,p.690.
p.56; March, p.139 The interplay between formai and informal IRS information
Federal income tax consequences of restructuring debt of gathering. Feb., p.83.
failing corporations after the Revenue Reconciliation The IRS summons as a Tax Court discovery tool. Aug.,
Act of 1990. April, p.214. p.501.
Gifts of inventory to charity. Oct., p.588.
Dividends
Incorporating intangible assets into the transfer price
Compensation or dividend distributions? Sept., p.546.
formula. Feb., p. 100.
Information reporting, record maintenance, and transfer Divorce
pricing. March, p.172. Section 1041—No recognition of gain or loss. July, p.438.
Interest accrual on an uncontested tax deficiency. Oct., Transfer of property between spouses or former spouses.
p.620. Jan., p.37; Jan., p. 41.
Loss carryovers in corporate bankruptcy reorganizations Employee Plans
under Prop. Reg. § 1.269-3(d). April, p.229. Spousal rollovers of retirement plan distributions. Aug.,
Notional principal contract income. June, p.343. p.513.
Proposed consolidated return regulations. July, p. 395. Employment Discrimination
Reorganization after General Utilities. Dec., p.882. Taxation of employment discrimination awards. Oct.,
RJR Nabisco “‘high yieid”’ securities exchange. Feb., p.74. p.608.
RJR Nabisco securities: Exchange of debentures for cash Environmental Issues ‘i
and common stock. April, p. 251.
Tax treatment of Superfund cleanups. Nov., p.682.
Salomon Phibro crude oil trust. July, p.416.
Estate and Retirement Planning
Spin-Offs: Divesting after General Utilities. Dec., p.€89.
Asset accumulation, retention and protection: Prelude to
Tax treatment of Superfund cleanups. Nov., p.682.
transmission. Dec., p.7 17.
The single entity theory of the consolidated Section 382
Charitable remainder trust. Feb., p. 106.
Regs. Dec., p.915.
Estate freezes. Jan., p.3; March, p.151.
The USX tracking stock spin-off.June, p.383.
Spousal rollovers of retirement pian distributions. Aug.,
Transfers between United States persons and foreign
p.513.
corporations pursuant to proposed Section 367 Regs.
Nov., p.671. Exempt Organizations
Valuation of closely held stock for transfer tax purposes: Gifts of inventory to charity. Oct., p.588.
Minority discounts for intrafamily transfers in family- Gifts of tangible personal property. Nov., p.706.
controlled corporations. May, p.309. Lobbying by exempt organizations. July, p.422.
Criminal Tax Finance
1082 TAXES /December 1991
Asset accumulation, retention and protection: Prelude to Passive Activity Losses
transmission. Dec., p.717. Proposed self-charged interest regulations. June, p.331.
Bifurcation of financial instruments. Dec., p.821.
Penalties
Computation of the corporate marginal tax rate. Oct.,
p.625. Accuracy-related and preparer penalties. May, p.259.
Avoiding accuracy-related and preparer penalties. June,
Hedging to minimize business risks. Dec., p.834.
p.351.
Payments in advance of performance. Dec., p.798.
Proposed Regs. for calculating underpayment or
Salomon Phibro crude oil trust. July, p.416. understatement. Sept., p.523.
Grantor Retained Income Trusts ... Jan., p.3; March, p.151; Policy
Dec., p.717. Tax treaty policy and Subpart F. Dec., p.1001.
Health Maintenance Organizations (HMOs)}——Tax status. The 1990 modifications to the low-income housing tax
Feb., p.90. credit, March, p.193.
Independent Contractor Practice and Procedure
Classification of workers. May, p. 319. Avoiding accuracy-related and preparer penalties. June,
p.351.
Interest
Bringing tacx cases in District Court. March, p. 167
Interest accrual on an uncontested tax deficiency. Oct.,
Finality of Tax Court decision. Aug., p.507.
p.620.
Proposed self-charged interest regulations. June, p.331. Immunized testimony and subsequent tax prosecutions.
Feb., p.67.
Payments in advance of performance. Dec., p.798.
Tax Court discovery rules and administrative summonses.
International Jan., p.19.
Classification of domestic and foreign entities indirectly Tax court discovery rules v. IRS summons authority——
owned by a single interest. Nov., p.659. the Ash case. Nov.,p.690.
Incorporating intangible assets into the transfer price The interplay between formal and informal IRS information
formula. Feb., p.100. gathering. Feb., p.83.
Information reporting, record maintenance, and transfer The IRS summons as a Tax Court discovery tool. Aug.,
pricing. March, p.172. p.501.
intercompany transfer pricing in the 1990s. Dec., p.961. Returns
Notional principal contract income. June, p.343. Accuracy-related and preparer penalties. May, p.259.
Repatriating earnings from foreign investments. Dec.,
Avoiding accuracy-related and preparer penalties. June,
p.1017. p.351.
Tax treaty policy and Subpart F. Dec., p.1001. Proposed consolidated return regulations. July, p.395.
The new theory and practice of Section 367. Dec., p.1008. Proposed Regs. for calculating underpayment or
Transfers between United States persons and foreign understatement. Sept., p.523.
corporations pursuant to proposed Section 367 Regs.
Revenue Reconciliation Act of 1990
Nov., p.671.
Federal income tax consequences of restructuring debt of
Limited Liability Companies failing corporations after the Revenue Reconciliation
Asset accumulation, retention and protection: Prelude to Act of 1990. April, p.214.
transmission. Dec., p.717. Tax planning considerations after the Revenue
The limited liability company: Beyond classification. April, Reconciliation Act of 1990. March, p.181.
p.203. The 1990 modifications to the iow-income housing tax
Loss credit. March, p.193.
Recent Supreme Court decisions clarify loss recognition S Corporations
concepts. Sept., p.533. An analysis of the proposed one class of stock
Low-income Housing Credit Regulations. April, p.236.
The 1990 modifications to the low-income housing tax Compensation or dividend distributions? Sept., p.546.
credit. March, p.193. Proposed self-charged interest regulations. June, p.331.
Mail Order Sales Taxation . . . Sept., p.541. Sales and Exchanges
Partnerships Deferred exchange regulations. Aug., p.451.
Amortizing term interests in partnership property and Disguised sale proposed regulations. Oct., p.579.
interests, April, p.244. Purchase of a co-op unit. Sept., p.558.
Classification of domestic and foreign entities indirectly Recent Supreme Court decisions clarify loss recognition
owned by a single interest. Nov., p.659. concepts. Sept., p.533.
Compensation or dividend distributions? Sept., p.546. RJR Nabisco high yield securities exchange. Feb., p.74.
Disguised sale proposed regulations. Oct., p.579. RJR Nabisco securities: Exchange of debentures for cash
Formation under the temporary Section 752 Regs. Feb., and common stock. April, p. 251.
p.116; Feb., p.129. Stock
Proposed self-charged interest regulations. June, p.331. An analysis of the proposed one class of stock
Taxability of a partnership interest received in exchange Regulations. April, p.236.
for services. Jan., p.13. Compensation or dividend distributions? Sept., p.546.
Taxation of a profits interest in a partnership. Nov., p.643. RJR Nabisco high yield securities exchange. Feb., p.74.
The limited liability company: Beyond classification, April, RJR Nabisco securities: Exchange of debentures for cash
p.203. and common stock, April, p. 251.
December 1991\ TAXES
The USX tracking stock spin-off. June, p.383. Partnership interests. Jan., p.13.
Transfers between United States persons and foreign Repeal of Section 2036(c). Jan., p.3.
corporations pursuant to proposed Section 367 Regs. Taxation of a profits interest in a partnership. Nov., p.643.
Nov., p.671. Valuation of closely held stock for transfer tax purposes:
Valuation of closely held stock for transfer tax purposes: Minority discounts for intrafamily transfers in family-
Minority discounts for intrafamily transfers in family- controlled corporations. May, p.309.
controlled corporations. May, p.309. Warrants and convertible debt in private taxable
Valuation acquisitions. Dec., p.866.
Title and Author Index
Each authored article appearing in TAXES during 1991 is indexed below to title and author. In addition,
unauthored features such as Tax Pointers are indexed to title, with the feature designation in parentheses.
A Boley, Richard and John O. Everett. Tax Policy
Micromanagement Ii (There They Go Again): The 1990
Modifications to the Low-income Housing Tax Credit.
AARP—Asset Accumulation, Retention and Protection:
Mar., p. 193.
Prelude to Transmission. Dec., p. 717.
Bolling, Rodger A. Treasury’s Attempted Repeal of Subchapter
Accepted Reorganization Concepts After General Utilities
S: An Analysis of the “One Class of Stock’’ Proposed
Repeal—Familiar Concepts in a Changed World. Dec., p.
Regulations. Apr., p. 236.
882.
Boshkov, Stefan R. Selected Federal Income Tax
Amortizing Term Interests in Partnership Property and
Partnership Interests. Apr., p. 244. Consequences of Restructuring Debt of Failing
Corporations After the Revenue Reconciliation Act of
Appeal Procedures for Erroneous Tax Lien Notices (Tax
1990. Apr., p. 214.
Pointer). June, p. 342.
Brandt, Michael G. and Steven J. Joffe. Dispositions of
Asimow, Miciiaei. Section 1041 Needs No Cure. Jan., p. 37.
Subsidiary Stock: Proposed Loss Disallowance
Auster, Rolf. Amortizing Term Interests in Partnership Property
Regulations Ante Up an Allowance. Mar., p. 139.
and Partnership Interests. Apr., p. 244.
Brazelton, Julia K. and Mark W. March. Superfund Cleanups:
The Financial Costs High, the Tax Treatment Uncertain.
B
Nov., p. 682.
Bringing Tax Cases in District Court: The Other Considerations
Baicerzak, Stephanie E. and Douglas H. Walter. Innovative
(Viewpoint). Mar., p. 167.
Transactions: Salomon Phibro Crude Oil Trust. July, p.
416. Burke. Karen C. Partnership Formation Under the Temporary
Section 752 Regulations: A Reply and Further Discussion.
Banoff, Sheldon |. Determining and Weighing Valid Legal
Feb., p. 116.
Authority to Avoid Accuracy-Related and Preparer
Penalties: The Proposed Regulations Continue the Butler, David H. Partnership Formation Under the Temporary
Controversy. May, p. 259. Section 752 Regulations: A Reply. Feb., p. 129.
Banoff, Sheldon |. and Harvey L. Coustan. Dodging the Bullet:
Avoiding the Accuracy-Related and Preparer Penalties Cc
Through Reasonable Cause and Good Faith, or
Disclosure. June, p. 351. Campbell v. Commissioner: is There Now ‘‘Little or No
Barrella, Vincent R. Curbing IRS Efforts to Circumvent Tax Chance”’ of Taxation of a ‘‘Profits’’ Interest in a
Court Discovery Limitations—The District Court as the Partnership? Nov., p. 643.
Proper Forum. Nov., p. 690. Carrybacks, Carryovers, and Ordering Rules——Calculating
Barrella, Vincent R. The Tax Court’s Westreco Opinion—Great Underpayments and Understatements: Proposed Penalty
for Nestle, but Is It the Very Best? Jan., p. 19. Regulations Carry On the Controversy. Sept., p. 523.
Battle, Frank V., Jr. Bifurcation of Financial Instruments. Dec., The Charitable Remainder Trust: A Unique Estate Planning
p. 821. Technique. Feb., p. 106.
Bell, Bruce E. Spousal Rollovers Require Selective Use and Clair, John J. Accepted Reorganization Concepts After
Careful Planning. Aug., p. 513. General Utilities Repeal——Familiar Concepts in a
Bifurcation of Financial instruments. Dec., p. 821. Changed World. Dec., p. 882.
Blanchard, Jerred G., Jr. The Single Entity Theory of the Clark, Michael A. Lost in the Hedge Row——Searching for
Consolidated Section 382 Regulations: A Study in Ordinary Results on Transactions to Minimize Business
Complexity. Dec., p. 915. Risks. Dec., p. 834. ;
1084 TAXES /December 1991
Cohen, Michael J. and Charles R. Levun. Mark IV Pictures, Inc.: Drobny, Sheldon. Finality of Tax Court Decision—Iin Search of
Scrambled Campbell. Jan., p. 13. the Meaning of Finality (Viewpoint). Aug., p. 507.
Commentary: The Nexus Wars. Sept., p. 541.
Compensation or Dividend Distributions? Sept., p. 546. E
The Complex Interplay of Tax Rate Provisions After RRA '90
and Tax Planning Considerations. Mar., p. 181. Economic Performance—The IRS Strikes with Proposed
Computation of the Corporate Marginai Tax Rate. Oct., p. 625. Regulations. Jan., p. 60.
“Condopping” a Co-op. Sept., p. 558. Engle, Howard S. Managing at the Repatriation Decision: The
Consolidated Section 382: The Proposed Regulations. July, p. Multinational’s Dilemma. Dec., p. 1017.
395. Englebrecht, Ted D. and Evelyn C. Hume. Partners Face New
Conway, Jeffrey D. Innovative Transactions: The USX Tracking Risks of Disguised Sale Treatment: An Analysis of the
Stock “Spin-Off,”: A Case of Split Personality. June, p. Recently Issued Proposed Regulations. Oct., p. 579.
383.
Entity Classification When a Purported Partnership Is
Copeland, Phyllis V. and Philip J. Harmelink. The Complex Ultimately Owned by One Corporation. Nov., p. 659.
Interplay of Tax Rate Provisions After RRA '90 and Tax
Estate Freezes 1990 and Beyond: The Story of the Repeal of
Planning Considerations. Mar., p. 181.
Section 2036(c) and the Valuation Rules That Took Its
Coustan, Harvey L. Carrybacks, Carryovers, and Ordering
Place. Jan., p. 3.
Rules—Caiculating Underpayments and Understatements:
Everett, John O. and Richard Boley. Tax Policy
Proposed Penalty Regulations Carry On the Controversy.
Micromanagement II (There They Go Again): The 1990
Sept., p. 523.
Modifications to the Low-income Housing Tax Credit.
Coustan, Harvey L. and Sheldon |. Banoff. Dodging the Bullet:
Mar., p. 193.
Avoiding the Accuracy-Related and Preparer Penalties
Through Reasonable Cause and Good Faith, or
Disclosure. June, p. 351. 5
Cuff, Terence Floyd. Campbell v. Commissioner: is There Now
“Little or No Chance”’ of Taxation of a “Profits” Interest in Finality of Tax Court Decision—in Search of the Meaning of
a Partnership? Nov., p. 643. Finality (Viewpoint). Aug., p. 507.
Cuff, Terence Floyd. Deferred Exchange Regulations. Aug., p. FSAs: Help for Employees in Era of Costly Benefits (Tax
451. Pointer). Sept., p. 555.
Curbing IRS Efforts to Circumvent Tax Court Discovery
Limitations—The District Court as the Proper Forum. G
Nov., p. 690.
Gall, Maryann B. Commentary: The Nexus Wars. Sept., p. 541.
D
Gardner, John H. Estate Freezes 1990 and Beyond: The Story
of the Repeal of Section 2036(c) and the Valuation Rules
The Deductibility of Takeover Costs After National Starch. That Took Its Place. Jan., p. 3.
Jan., p. 48.
Gidilund, Gordon L. The Raikos Irony and How the IRS Seeks
Dees, Richard L. The Slaying of Frankenstein’s Monster: The
Tax Truth. Feb., p. 83.
Repeal and Replacement of Section 2036(c). Mar., p. 151.
Gould, Arthur |. Spin-Offs: Divesting in a Post-General Utilities
Deferred Exchange Regulations. Aug., p. 451.
World, with Emphasis on Practical Problems. Dec., p. 889.
Determining and Weighing Valid Legal Authority to Avoid
Greenstein, Brian R. The Deductibility of Takeover Costs After
Accuracy-Related and Preparer Penalties: The Proposed
National Starch. Jan., p. 48.
Regulations Continue the Controversy. May, p. 259.
Dilworth, Robert H., L.G. Harter and Jeffrey M. O’Donnell. New Greenstein, Brian R. and Mark B. Perseilin. Compensation or
United States Source Rules for Notional Principal Contract Dividend Distributions? Sept., p. 546.
income. June, p. 343.
Dispositions of Subsidiary Stock: Proposed Loss Disallowance H
Regulations Ante Up an Allowance. Mar., p. 139.
The Dispute Over Taxation of Employment Discrimination Harmelink, Philip J. and Phyllis V. Copeland. The Complex
Awards. Oct., p. 608. Interplay of Tax Rate Provisions After RRA '90 and Tax
Divorce and Section 1031: How to Fix Two of the Problems Planning Considerations. Mar., p. 181.
Left by Section 1041. Jan., p. 41. Harrison, Louis S. and John M. Janiga. Valuation of Closely
Dodging the Bullet: Avoiding the Accuracy-Related and Held Stock for Transfer Tax Purposes: The Current Status
Preparer Penalties Through Reasonable Cause and Good of Minority Discounts for Intrafamily Transfers in Family-
Faith, or Disclosure. June, p. 351. Controlled Corporations. May, p. 309.
December 1991\ TAXES
Harter, L.G., Robert H. Dilworth and Jeffrey M. O'Donnell. New Joffe, Steven J. and Michael G. Brandt. Dispositions of
United States Source Rules for Notional Principal Contract Subsidiary Stock: Proposed Loss Disallowance
income. June, p. 343 Regulations Ante Up an Allowance. Mar., p. 139.
Hoffman, Michael J.R., S. Theodore Reiner and Karen S. Jordan, Martha W. and Peter K. Kloepfer. The Limited Liability
McKenzie. in Kind Giving: Tax and Accounting Aspects of Company: Beyond Classification. Apr., p. 203.
Giving Inventory Property to Charity. Oct., p. 588.
Hoke, William D. Proposed Section 367 Regs.—Broader Scope K
and Less Deferral. Nov., p. 671.
Hume, Evelyn C. and Ted D. Englebrecht. Partners Face New Kanter, Burton W. AARP—Asset Accumulation, Retention and
Risks of Disguised Sale Treatment: An Analysis of the Protection: Prelude to Transmission. Dec., p. 717.
Recently issued Proposed Regulations. Oct., p. 579. Kauffman, Stephen P. The impact of Energy Resources and
Begier on IRS Policy Statement P-5-60. Jan., p. 31.
Kimball, Christian E. Taxing Uncertainty: Warrants and
Convertible Debt in Private Taxable Acquisitions. Dec., p.
866.
Immunized Testimony and Subsequent Tax Prosecutions:
Kingson, Charles |. The New Theory and Practice of Section
What's the Use of Use Immunity? Feb., p. 67.
367. Dec., p. 1008.
The Impact of Energy Resources and Begier on IRS Policy
Kloepfer, Peter K. and Martha W. Jordan. The Limited Liability
Statement P-5-60. Jan., p. 31.
Company: Beyond Classification. Apr., p. 203.
In Kind Giving: Tax and Accounting Aspects of Giving
Kusma, Kyllikki and Cheryl K. Jackson. Lobbying by Exempt
Inventory Property to Charity. Oct., p.588.
Organizations: A Realistic Alternative to the ‘‘Substantial
Incorporating Intangible Assets into the Transfer Price Part” Test. July, p. 422.
Formula. Feb., p. 100.
Independent Contractor: A Legitimate Classification with L
Reclassification Protection. May, p. 319.
Information Reporting, Record Maintenance, and Transfer Lai, Richard T. Reducing Net Earnings of Self-Employment
Pricing Audits of Foreign and Foreign-Owned Activities. June, p. 372.
Corporations. Mar., p. 172. Levun, Charles R. and Michael J. Cohen. Mark IV Pictures, Inc.:
innovative Transactions: Salomon Phibro Crude Oil Trust. July, Scrambled Campbell. Jan., p. 13.
p. 416. The Limited Liability Company: Beyond Classification. Apr., p.
Innovative Transactions: The USX Tracking Stock ‘Spin-Off’: 203.
A Case of Split Personality. June, p. 383. Lipton, Richard M. IRS Issues Proposed Regulations
Permitting Self-Charged Interest. June, p. 331.
Intercompany Transfer Pricing in the 1990s: Trading Old
Lamps for New Ones? Dec., p. 961. Lipton, Richard M. The Tax Consequences to a Debtor from a
Transfer of Its Indebtedness. Dec., p. 939.
Internal Revenue Code Section 1041 Is Anything But Model
Tax Reform Legislation. July, p. 438. Lobbying by Exempt Organizations: A Realistic Alternative to
the ‘Substantial Part’’ Test. July, p. 422.
IRS Issues Proposed Regulations Permitting Self-Charged
Loss Carryovers in Corporate Bankruptcy Reorganizations
Interest. June, p. 331.
Under Prop. Reg. § 1.269-3(d). Apr., p. 229.
IRS Perpetuates Confusion over the Tax Status of Health
Lost in the Hedge Row: Searching for Ordinary Results on
Maintenance Organizations. Feb., p. 90.
Transactions to Minimize Business Risks. Dec., p. 834.
The IRS Summons as a Tax Court Discovery Tool: Another
Perspective. Aug., p. 501.
M
J
Managing at the Repatriation Decision: The Multinational’s
Dilemma. Dec., p. 1017.
Jackson, Cheryl K. and Kyillikki Kusma. Lobbying by Exempt March, Mark W. and Julia K. Brazelton. Superfund Cleanups:
Organizations: A Realistic Alternative to the “Substantial The Financial Costs High, the Tax Treatment Uncertain.
Part” Test. July, p. 422. Nov., p. 682.
Jaeger, David G. The Dispute Over Taxation of Employment Mark IV Pictures, Inc.: Scrambled Campbell. Jan., p. 13.
Discrimination Awards. Oct., p. 608. Maydew, Gary L. Economic Performance—The IRS Strikes
Janiga, John M. and Louis S. Harrison. Valuation of Closely with Proposed Regulations. Jan., p. 60.
Held Stock for Transfer Tax Purposes: The Current Status McClellan, Janice E. and Janet A. Meade. Loss Carryovers in
of Minority Discounts for Intrafamily Transfers in Family- Corporate Bankruptcy Reorganizations Under Prop. Reg.
Controlled Corporations. May, p. 309. § 1.269-3(d). Apr., p. 229.
1086 TAXES /December 1991
McKenzie, Karen S., S. Theodore Reiner and Michael J.R. Podris, Katherine D. and Gary J. Podris. Internal Revenue
Hoffman. In Kind Giving: Tax and Accounting Aspects of Code Section 1041 Is Anything But Model Tax Reform
Giving Inventory Property to Charity. Oct., p. 588. Legislation. July, p. 438.
Meade, Janet A. and Janice E. McClellan. Loss Carryovers in Proposals Address Expense Election Limits (Tax Pointer). July,
Corporate Bankruptcy Reorganizations Under Prop. Reg. p. 442.
§ 1.269-3(d). Apr., p. 229. Proposed Section 367 Regs.—Broader Scope and Less
Miller, Ward. RJR Nabisco “High Yield” Securities: Coping Deferral. Nov., p. 671.
with an Income Tax Nightmare. Feb., p. 74. Pulliam, Dale R. and Darlene A. Smith. A Replacement for Reg.
Miller, Ward. RJR Nabisco Securities: Exchange of Debentures § 1.1502-20T: The Continuing Saga of the Mirror Family
for Cash and Common Stock (March 1991) (Author’s (Authors’ Update). Jan., p. 56.
Update). Apr., p. 251.
Mogle, James R. Intercompany Transfer Pricing in the 1990s: R
Trading Old Lamps for New Ones? Dec., p. 961.
Morrison, Philip D. Talking Past Each Other on Tax Treaty The Raikos \lrony and How the IRS Seeks Tax Truth. Feb., p.
Policy and Subpart F. Dec., p. 1001. 83.
Recent Supreme Court Decisions Clarify Recognition of Loss
N Concepts. Sept., p. 533.
Reducing Net Earnings of Self-Employment Activities. June, p.
372.
Neal, Philip S. IRS Perpetuates Confusion over the Tax Status
of Health Maintenance Organizations. Feb., p. 90. Reiner, S. Theodore, Karen S. McKenzie and Michael J.R.
Hoffman. In Kind Giving: Tax and Accounting Aspects of
The New Theory and Practice of Section 367. Dec., p. 1008.
Giving Inventory Property to Charity. Oct., p. 588.
New United States Source Rules for Notional Principal
A Replacement for Reg. § 1.1502-20T: The Continuing Saga of
Contract income. June, p. 343.
the Mirror Family (Author’s Update). Jan., p. 56.
Nunamaker, Thomas R. and Richard B. Toolson. Computation
Riggall, Kneave. Divorce and Section 1031: How to Fix Two of
of the Corporate Marginal Tax Rate. Oct., p. 625.
the Problems Left by Section 1041. Jan., p. 41.
RJR Nabisco “High Yield’”’ Securities: Coping with an Income
O
Tax Nightmare. Feb., p. 74.
RJR Nabisco Securities: Exchange of Debentures for Cash and
O'Donnell, Jeffrey M., Robert H. Dilworth and L.G. Harter. New Common Stock (March 1991) (Author’s Update). Apr., p.
United States Source Rules for Notional Principal Contract 251.
Income. June, p. 343.
Roberts, William A. Bringing Tax Cases in District Court: The
Oden, Debra Hall. Independent Contractor: A Legitimate Other Considerations (Viewpoint). Mar., p. 167.
Classification with Reclassification Protection. May, p. Rosenblatt, Leonard R. immunized Testimony and Subsequent
319.
Tax Prosecutions: What’s the Use of Use Immunity? Feb.,
p. 67.
P
Ss
Partners Face New Risks of Disguised Sale Treatment: An
Analysis of the Recently Issued Proposed Regulations. Scarborough, Robert. Payments in Advance of Performance.
Oct., p.579. Dec., p. 798.
Partnership Formation Under the Temporary Section 752 Schmidt, Dennis R. and Thomas C. Pearson. Information
Regulations: A Reply and Further Discussion. Feb., p. 116. Reporting, Record Maintenance, and Transfer Pricing
Partnership Formation Under the Temporary Section 752 Audits of Foreign and Foreign-Owned Corporations. Mar.,
Regulations: A Reply. Feb., p. 129. p. 172.
Payments in Advance of Performance. Dec., p. 798. Section 1041 Needs No Cure. Jan., p. 37.
Pearson, Thomas C. and Dennis R. Schmidt. Information Segal, Mark A. Recent Supreme Court Decisions Clarify
Reporting, Record Maintenance, and Transfer Pricing Recognition of Loss Concepts. Sept., p. 533.
Audits of Foreign and Foreign-Owned Corporations. Mar., Selected Federal Income Tax Consequences of Restructuring
p. 172. Debt of Failing Corporations After the Revenue
Persellin, Mark B. and Brian R. Greenstein. Compensation or Reconciliation Act of 1990. Apr., p. 214.
Dividend Distributions? Sept., p. 546. Shanda, Lawrence P. Incorporating Intangible Assets into the
Podris, Gary J. and Katherine D. Podris. Internal Revenue Transfer Price Formula. Feb:, p. 100.
Code Section 1041 Is Anything But Model Tax Reform Silberberg, Marc L. Consolidated Section 382: The Proposed
Legislation. July, p. 438. Regulations. July, p. 395.
December 1991\TAXES
Silverman, Elliot. Turning the Other Cheek: Tax Fraud, Tax Taxing Uncertainty: Warrants and Convertible Debt in Private
Protest, and the Willfulness Requirement. May, p. 302. Taxable Acquisitions. Dec., p. 866.
The Single Entity Theory of the Consolidated Section 382 Taylor, Jeffery S. The Charitable Remainder Trust: A Unique
Regulations: A Study in Complexity. Dec., p. 915. Estate Planning Technique. Feb., p. 106.
The Slaying of Frankenstein’s Monster: The Repeal and Tilevitz, Orrin. ““Condopping” a Co-op. Sept., p. 558.
Replacement of Section 2036(c). Mar., p. 151.
Toolson, Richard B. and Thomas R. Nunamaker. Computation
Smith, Darlene A. and Dale R. Pulliam. A Replacement for Reg.
of the Corporate Marginal Tax Rate. Oct., p. 625.
§ 1.1502-20T: The Continuing Saga of the Mirror Family
(Author’s Update). Jan., p. 56. Treasury's Attempted Repeal of Subchapter S: An Analysis of
the “One Class of Stock” Proposed Regulations. Apr., p.
Spin-Offs: Divesting in a Post-General Utilities Worid, with
236.
Emphasis on Practical Problems. Dec., p. 889.
Turning the Other Cheek: Tax Fraud, Tax Protest, and the
Spousal Rollovers Require Selective Use and Careful Planning.
Willfulness Requirement. May, p. 302.
Aug., p. 513.
Spudis, Barbara C. and Michael J. Wilczynski. Entity
Classification When a Purported Partnership Is Ultimately V
Owned by One Corporation. Nov., p. 659.
Stein, Ronald A. The IRS Summons as a Tax Court Discovery Valuation of Closely Held Stock for Transfer Tax Purposes:
Tool: Another Perspective. Aug., p. 501. The Current Status of Minority Discounts for Intrafamily
Transfers in Family-Controlied Corporations. May, p. 309.
Stein, Ronald A. When Does Interest Accrue on an
Uncontested Tax Deficiency? Oct., p. 620.
Ww
Superfund Cleanups: The Financial Costs High, the Tax
Treatment Uncertain. Nov., p. 682.
Walter, Douglas H. and Stephanie E. Balcerzak. innovative
T Transactions: Salomon Phibro Crude Oil Trust. July, p.
416.
Talking Past Each Other on Tax Treaty Policy and Subpart F. When Does Interest Accrue on an Uncontested Tax
Deficiency? Oct., p.620.
Dec., p. 1001.
The Tax Consequences to a Debtor from a Transfer of Its Wilczynski, Michael J. and Barbara C. Spudis. Entity
indebtedness. Dec., p. 939. Classification When a Purported Partnership Is Ultimately
Owned by One Corporation. Nov., p. 659.
The Tax Court’s Westreco Opinion——Great for Nestle, but Is
It the Very Best? Jan., p. 19. Window of Opportunity for Gifts of Tangible Personal Property.
Nov., p. 706.
Tax Policy Micromanagement Ii (There They Go Again): The
1990 Modifications to the Low-Income Housing Tax Wittenbach, James L. Window of Opportunity for Gifts of
Credit. Mar., p. 193. Tangible Personal Property. Nov., p. 706.
TAXES /December 1991
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