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Vol. 72, No. 2 (Winter 2019)

CONTENTS

REPORTS

Initial Comments Concerning the Aggregation and Disaggregation of Trade or Business Activities for Purposes of Section 199A
American Bar Association Section of Taxation

Comments Concerning the Specialized Service Trade or Business Activities for Purposes of Section 199A
American Bar Association Section of Taxation

Comments Concerning the Treatment of Losses and Certain Other Issues Regarding the Section 199A Deduction
American Bar Association Section of Taxation

ARTICLES

Proposal for a Non-Subsidized, Non-Retirement-Plan, Employee-Owned Investment Vehicle to Replace the ESOP
Sean Anderson and Andrew Morrison Stumpff
Abstract

The Compulsory Tax Constraint for Foreign Tax Credits Post TCJA & Coca-Cola Co. v. Commissioner
Philip G. Cohen
Abstract

Asset Basis In Acquisitive Reorganizations: General Utilities Hangover
David Hasen
Abstract

No Orchard, No Capital Gain
Calvin H. Johnson
Abstract

In Defense of the PIP Regulations
Walter D. Schwidezky
Abstract

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