Section of Taxation Publications
  VOL. 53
NO. 3
SPRING 2000

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ARTICLESSection Members Only
Tax Benefits, Tax Administration, and Legislative Intent
David P. Hariton
 
Full Article
The Role of Prescription in the Interpretive Problem of Basis Determination
Anthony P. Polito
 
Full Article
What is Tax Treaty Abuse? (Is Treaty Shopping an Outdated Concept?)
Richard L. Reinhold
 
Full Article
Capital Gain v. Ordinary Income and the FICA Tax Treatment of Employee Stock Purchase Plans
Kevin Wiggins
 
Full Article
LECTURE
2000 Erwin N. Griswold Lecture Before the American College of Tax Counsel:
How Will a Court Rule?
M. Carr Ferguson
 
 
Full Article
REPORT
Standards of Tax Practice Statement
American Bar Association Section of Taxation Committee on the Standards of Tax Practice
 
 
Full Article
NOTES
Collateral Estoppel Defense Disallowed When Not Initially Raised During Administrative Proceeding: True v. United States
Daniel K. Chang

 
 
Full Article
Foreign Tax Credit Denied To Sham Tax Avoidance Transaction: Compaq v. Commissioner
Clifford D. Cohn

 
Full Article
Payments to Employees of Closely Held Corporation Not Deductible under Section 162(a)(1) When They Represent Disguised Dividends: O.S.C. & Associates, Inc. v. Commissioner
Evan R. Fleck

 
Full Article
A Framework for Determining Priority of Tax Liens Pursuant to Section 6323: Amato v. United States
Matthew Freimuth

 
Full Article
Assessing Employer FICA Tax on the Estimated Aggregate Unreported Tips of Employees: Quietwater Entertainment, Inc. v. United States
Jonathan H. Lehr

 
Full Article
Equitable Recoupment-Is it Beyond the Tax Court’s Jurisdiction?: Estate of Branson v. Commissioner
Luis C. Marini

 
Full Article
Gain-Triggering Abandonment of Leasehold Subject to Nonrecourse Debt Occurred upon Agreement Transferring Substantive Ownership: L & C Springs Associates v. Commissioner
Nina S. Tallon

 
Full Article
Act of State Doctrine Allows Foreign Taxes on "Net Loan" Interest Paid by a Foreign Central Bank to be Credited as a Foreign Tax Credit: Riggs National Corp. v. Commissioner
Mark Vincent Vlasic
Full Article
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Published by
Section of Taxation, American Bar Association
With the Assistance of
Georgetown University Law Center

 

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