Published by Section of Taxation, American Bar Association With the Assistance of Georgetown University Law CenterIf you are an ABA member, you can receive The Tax Lawyer and the Section Newsletter, both quarterly publications, when you join the Section of Taxation. To enroll, click here. 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. |