Section of Taxation Publications

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The Tax Lawyer
VOL. 52 NO. 1
FALL 1998


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Published by
Section of Taxation, American Bar Association
With the Assistance of
Georgetown University Law Center


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


Comments Regarding Retention of the Consolidated Return SRLY Rules
American Bar Association Section of Taxation Committee on Affiliated and Related Corporations


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