Volume 59, No. 3 - Spring 2006

Articles

Report of the Task Force on International Tax Reform

ABA Section of Taxation

The American Bar Association Section of Taxation convened the Task Force on International Tax Reform to provide policymakers with objective criteria by which to evaluate reform proposals and to identify and analyze possible specific modifications to the U.S. international tax rules. This Report considers the taxation of U.S. persons' foreign business income. ...

Taxing Undocumented Immigrants: Separate, Unequal, and Without Representation

Francine J. Lipman

Americans believe that undocumented immigrants are exploiting the United States economy. The widespread belief is that "illegal aliens" cost more in government services than they contribute to the economy. This belief is undeniably false. ...

Fallacies of Presumption: Unpacking the Impact of the Section 409A Proposed Regulations on Stock Appreciation Tights Issued By Privately-Held Companies

Vanessa A. Scott

For decades, nonqualified deferred compensation plans were subject to limited government regulation. However, in the last five years these plans have received considerable scrutiny from both Congress and the Department of Treasury. ...

Notes

Making Your Business Fly Above Section 183: Fair Skies Following Rabinowitz v. Commissioner

Jeremiah B. Frueauf

So-called "hobby-loss" cases have long created confusion for taxpayers and tax-planners alike. Though taxpayers attempt to carefully structure certain activities to avoid the hobby-loss restrictions of section 183, the Service frequently and often unpredictably disallows losses attributable to such activities. ...

Strict Divestiture Requirements In Section 6324(a)(1): First American Title v. United Satates and the Hazard of the Special Estate Tax Lien

Jeanette Quick

In First American Title Insurance Company v. United States, a federal district court addressed the requirements for divestiture of special estate tax liens. Under section 6324(a)(1), a special estate tax lien divests when the sale proceeds are used to satisfy charges against the estate...

Right Without Reason? The Check-The-Box Corporate or Partnership Election Regulations Correctly Held Valid: Littriello v. United States

William J. Rowe

In Littriello v. United States, the District Court for the Western District of Kentucky became the first court to uphold the popular check-the-box regulations, Treasury Regulations 301.7701-1 through 301.7701-3. The check-the-box regulations allow small businesses...

No M.B.A. Left Behind: Professional Education as a Business Expense in Allemeier v. Commissioner

Robert A. Stolworthy, Jr.

In Allemeier v. Commissioner, the Tax Court upheld a deduction for the cost of acquiring a Masters in Business Administration as an ordinary and necessary business expense. In its memorandum decision, the court allowed the deduction after finding...

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Vol. 59, No. 3 - Spring 2006

The Tax Lawyer, Spring 2006

Articles

Report of the Task Force on International Tax Reform

Taxing Undocumented Immigrants: Separate, Unequal, and Without Representation

Fallacies of Presumption: Unpacking the Impact of the Section 409A Proposed Regulations on Stock Appreciation Tights Issued By Privately-Held Companies

Notes

Making Your Business Fly Above Section 183: Fair Skies Following Rabinowitz v. Commissioner

Strict Divestiture Requirements In Section 6324(a)(1): First American Title v. United Satates and the Hazard of the Special Estate Tax Lien

Right Without Reason? The Check-The-Box Corporate or Partnership Election Regulations Correctly Held Valid: Littriello v. United States

No M.B.A. Left Behind: Professional Education as a Business Expense in Allemeier v. Commissioner

The Tax Lawyer

Subscribing

American Bar Association TM American Bar Association

Vol. 59, No. 3 - Spring 2006

The Tax Lawyer, Spring 2006

Articles

Report of the Task Force on International Tax Reform

Taxing Undocumented Immigrants: Separate, Unequal, and Without Representation

Fallacies of Presumption: Unpacking the Impact of the Section 409A Proposed Regulations on Stock Appreciation Tights Issued By Privately-Held Companies

Notes

Making Your Business Fly Above Section 183: Fair Skies Following Rabinowitz v. Commissioner

Strict Divestiture Requirements In Section 6324(a)(1): First American Title v. United Satates and the Hazard of the Special Estate Tax Lien

Right Without Reason? The Check-The-Box Corporate or Partnership Election Regulations Correctly Held Valid: Littriello v. United States

No M.B.A. Left Behind: Professional Education as a Business Expense in Allemeier v. Commissioner

The Tax Lawyer

Subscribing