Section of Taxation Publications
  VOL. 52
NO. 4

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Are Separate Liability Losses Separate for Consolidated Groups?
Don Leatherman

The A.L.I. Tax Treaty Study—A Critique and a Modest Proposal
Philip F. Postlewaite
David S. Makarski


The Tax Implications of Catching Mark McGwire's 62 nd Home Run Ball


Lawsuit Proceeds Were Ordinary Income: Nahey v. Commissioner

Grant of Easement in Family Farm Triggers Section 2032A Recapture Tax:
Estate of Gibbs v. United States

Taxpayer Was Entitled to Nonrecognition of Gain Under Section 1035 on the Partial Exchange of an Annuity: Conway v. Commissioner

Former Member of a Controlled Group Can Deduct Loss on an Intercompany Sale:
Turner Broadcasting System, Inc. v. Commissioner

Equitable Tolling Applies in Section 6532(c) in Third-Party Wrongful Levy Actions:
Becton Dickinson & Co. v. Wolckenhauer

Fair Market Value of Appreciated Property Distribution to Shareholders Determined Based on Form of Distribution Out of Corporation, Not on Reform Received by Shareholders:
Pope & Talbot, Inc. v. Commissioner


Important Developments During the Year


Volume 52, Numbers 1, 2, 3 and 4


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


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