Section of Taxation Publications

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The Tax Lawyer
VOL. 52 NO. 3
SPRING 1999

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

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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.