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Tax Lawyer, Vol. 57, No. 1 COSTANZA PROVIDES ADDITIONAL CERTAINTY TO SCIN TRANSACTIONS 163 163 BY GEORGE! COSTANZA PROVIDES ADDITIONAL CERTAINTY TO SCIN TRANSACTIONS Daniel W. Matthews* I. INTRODUCTION Over two decades have passed since the Tax Court’s seminal decision in Estate of Moss v. Commissioner,1 which held that the value of a bona fide self cancelling installment note (SCIN) is not includible in the gross estate of its holder. Since that time, several commentators have attempted to...

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