Volume 56, No. 2 - Winter 2003

Articles

Allocation and Reallocation in Accordance with the Partners' Interests in the Partnership

Stephen Utz

If a partnership agreement either fails to allocate an item of partnership income, gain, deduction, credit, or loss, or does so invalidly, section 704(b) requires the item to be allocated "in accordance with the partners' interests in the partnership." ...

Contributions, Distributions, and Assumption of Liabilities: Confronting Economic Reality

Karen C. Burke

To combat a relatively arcane international tax-shelter abuse, Congress recently amended sections 357 and 362 governing contributions of encumbered property to a corporation. The 1999 amendments were designed primarily to shut down attempts to create artificial basis...

Phantom Tax Regulations: The Curse of Spurned Delegations

Phillip Gall

The phone rings. The concerned voice on the other end asks whether doing "X, Y & Z" will cause a "tax disaster." You vaguely recall something about "X, Y & Z," so you request time to investigate. As you return the telephone receiver to its cradle...

Notes

A Strain Between the Contested Tax Liability Accrual Doctrine and the Accumulated Earnings Tax: Metro Leasing and Development Corporation v. Commissioner

Rusty Brewer

In Metro Leasing and Development Corp. v. Commissioner, the Tax Court held that no part of a paid, but contested, income tax deficiency could be used to reduce the taxpayer's taxable income in arriving at accumulated earnings taxable income. ...

Discounting Discounts: The Tax Court's Treatment of Family Partnership Gift Valuation in Estate of Jones v. Commissioner

Jakob Halpern

In Estate of Jones v. Commissioner, the Tax Court considered the transfer of interests in two family limited partnerships to the taxpayer's children. The court held that the initial transfers of property to the partnership were not gifts upon formation...

The Applicability of a Market Approach Valuation Analysis That Employs Only A Single Comparable: Heck v. Commissioner

Marc Samuel

In Estate of Heck v. Commissioner, the Tax Court refused to adopt the Service's application of the market approach as part of a closely held company's valuation where the expert relied on only one comparable company. Instead, the court relied exclusively...

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Vol. 56, No. 2 - Winter 2003

The Tax Lawyer, Winter 2003

Articles

Allocation and Reallocation in Accordance with the Partners' Interests in the Partnership

Contributions, Distributions, and Assumption of Liabilities: Confronting Economic Reality

Phantom Tax Regulations: The Curse of Spurned Delegations

Notes

A Strain Between the Contested Tax Liability Accrual Doctrine and the Accumulated Earnings Tax: Metro Leasing and Development Corporation v. Commissioner

Discounting Discounts: The Tax Court's Treatment of Family Partnership Gift Valuation in Estate of Jones v. Commissioner

The Applicability of a Market Approach Valuation Analysis That Employs Only A Single Comparable: Heck v. Commissioner

The Tax Lawyer

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Vol. 56, No. 2 - Winter 2003

The Tax Lawyer, Winter 2003

Articles

Allocation and Reallocation in Accordance with the Partners' Interests in the Partnership

Contributions, Distributions, and Assumption of Liabilities: Confronting Economic Reality

Phantom Tax Regulations: The Curse of Spurned Delegations

Notes

A Strain Between the Contested Tax Liability Accrual Doctrine and the Accumulated Earnings Tax: Metro Leasing and Development Corporation v. Commissioner

Discounting Discounts: The Tax Court's Treatment of Family Partnership Gift Valuation in Estate of Jones v. Commissioner

The Applicability of a Market Approach Valuation Analysis That Employs Only A Single Comparable: Heck v. Commissioner

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect