Vol. 21 No. 3 - Spring 2002

From the Chair

Taxation

From the Chair

Richard M. Lipton

This is my next-to-last column as the Chair of the Tax Section. In this column, I thought it would be appropriate, in addition to providing an update on recent Section activities, to share my thoughts concerning the role that the Tax Section can and should play within the American Bar Association...

From the Editor

Taxation

From the Editor

Alice G. Abreu

Things seem to be settling into a serene, if different, order all around us, and the Tax Section is no exception. The Midyear meeting has come and gone and the May meeting is nearly upon us. Significant changes in the Section’s meeting schedule are being implemented and we are looking forward to three informative Section–only meetings per year. ...

Council Actions

Taxation

Council Actions

N. Susan Stone

The Council of the ABA Section of Taxation met on January 17, 2002, at the Midyear Meeting of the ABA Section of Taxation, in New Orleans, Louisiana. The Council heard reports and took actions on the following topics. ...

Points to Remember

Taxation

The Service Renews Its Crackdown on Taxpayers Who Make Tax Refund Claims Based on Entitlement to Slavery Reparations

David A. Brennen

In a recent news release (Release No: IR-2002-08), the Service issued a “nationwide warning for taxpayers not to be misled into filing slavery reparations claims.” The apparent impetus for the warning was the large number of taxpayer claims for refunds related to slavery reparations, as the Service reported that it received nearly 80,000 tax returns...

Taxation

New Waiver Standard Under Deduction/Credit Disallowance Regulations for Failure to File Timely Returns

Nancy Beckner

Sections 874(a) and 882(c)(2) have long required nonresident alien individuals and foreign corporations to file true and accurate returns (in the manner prescribed by subtitle F) in order to claim otherwise allowable deductions and credits in computing taxable income which is effectively connected with the conduct of a trade or business within the United States. ...

Taxation

Charitable Gift Annuities: An Especially Attractive Alternative

Alexander Drapatsky

Often, when clients approach attorneys to inquire about the best way to structure a significant charitable gift, clients receive information about charitable remainder trusts (“CRTs”) or private foundations. Using such vehicles to make charitable gifts can result in significant charitable deductions and provide income streams for the donor...

Point & Counterpoint: The Attorney-Client Privilege in Tax Matters

Taxation

Point: Abolish the Attorney-Client Privilege in Tax Transactional Settings

Bruce Kayle

Courts have unfailingly and without question applied the attorney-client and work-productprivileges to tax-related matters in the same way the privileges would apply in non-tax matters. It is fair to ask, however, whether there are not differences between tax and non-tax law that would merit application of the privileges differently. ...

Taxation

Counterpoint: The Privilege Should Continue to Apply to Tax Transactional Communications

Carolyn Joy Lee

My esteemed colleague is absolutely correct in asserting that “tax law touches the economic affairs of just about every single person and business enterprise in the country.” It is for precisely this reason that the ability to consult confidentially with one’s tax adviser is vital to the ongoing integrity of our tax system. ...

Interview

Taxation

Congressman Ben Carding (D. MD.)

Jasper L. Cummings, Jr. and Alan J.J. Swirski

Benjamin L. Cardin has represented Maryland’s Third Congressional District in the House of Representatives since 1987. He is a member of the Ways and Means Committee, Ranking Member of the Human Resources Subcommittee, and a member of the Social Security Subcommittee. ...

Spotlight on Committees

Taxation

Young Lawyers Forum

ABA Section of Taxation

The Young Lawyers Forum (YLF) was created in May 2000 to serve as a point of entry for young lawyers and law students into the Tax Section. The goals of the YLF are as follows...

Distinguished Service Award

Taxation

2002 Distinguished Service Award Recipient: James P. Holden

Stefan F. Tucker

On May 11, the American Bar Association Section of Taxation will present its Distinguished Service Award for 2002 to James P. Holden. Jim is a partner at the Washington, DC-based law firm of Steptoe & Johnson, LLP. He formerly served as Chair of the Firm and as head of its tax practice. ...

Section Resolutions

Taxation

Section Resolutions

ABA Section of Taxation

The following legislative recommendation will be submitted for consideration by the ABA House of Delegates at the 2002 Annual Meeting in Washington, DC, contingent upon approval of the membership of the Section of Taxation at its May Meeting Plenary Session. To review the full report, please visit the Section’s website...

News Briefs

Taxation

News Briefs

ABA Section of Taxation

Tax Section news and announcements.

American Bar Association TM American Bar Association

Vol. 21 No. 3 - Spring 2002

Newsletter, Vol. 21 No. 3

From the Chair

From the Chair

From the Editor

From the Editor

Council Actions

Council Actions

Points to Remember

The Service Renews Its Crackdown on Taxpayers Who Make Tax Refund Claims Based on Entitlement to Slavery Reparations

New Waiver Standard Under Deduction/Credit Disallowance Regulations for Failure to File Timely Returns

Charitable Gift Annuities: An Especially Attractive Alternative

Point & Counterpoint: The Attorney-Client Privilege in Tax Matters

Point: Abolish the Attorney-Client Privilege in Tax Transactional Settings

Counterpoint: The Privilege Should Continue to Apply to Tax Transactional Communications

Interview

Congressman Ben Carding (D. MD.)

Spotlight on Committees

Young Lawyers Forum

Distinguished Service Award

2002 Distinguished Service Award Recipient: James P. Holden

Section Resolutions

Section Resolutions

News Briefs

News Briefs