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Tax Lawyer, Vol. 56, No. 2 CONFRONTING ECONOMIC REALITY 383 383 CONTRIBUTIONS, DISTRIBUTIONS, AND ASSUMPTION OF LIABILITIES: CONFRONTING ECONOMIC REALITY Karen C. Burke* I. INTRODUCTION To combat a relatively arcane international tax-shelter abuse, Congress recenntl amended sections 357 and 362 governing contributions of encumbered property to a corporation.1 The 1999 amendments were designed primarily to shut down attempts to create artificial basis by manipulating the liability assumpptio rules...

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