Section of Taxation Publications
  VOL. 59
NO. 1
FALL 2005

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ARTICLESSection Members Only

LIFO Recapture on C-to-S Conversions:
Filling the Gaps and Ameliorating the Deficiencies of Section 1363(d)

David W. LaRue, Ph.D.

Full Article
Underwater Assets and Insolvent Corporations:
Reflections on Treasury’s Recently Proposed Regulations and Related Matters

Jerred G. Blanchard, Jr.
Kenneth L. Hooker
Gary R. Vogel

Full Article

Judicial Application of Issue Preclusion in Tax Litigation:
Illusion or Illumination?

Gover Hartt, III
Jonathan L. Blacker

Full Article
Defying Expectations:
Assessing the Surprising Resilience of State Death Taxes

Robert Yablon
Full Article
Sincerity & Credibility: The True Concerns in Assessing Willfulness –
An Analysis and Criticism of United States v. Pensyl

Donald E. Field
Full Article
The Narrowed Reasonable Cause Standard in Section 6651(a)(2):
Estate of Hartsell v. Commissioner

Mark Roche
Full Article
Altering the Alter Ego Doctrine: Misapplication and Gender
Issues in Spotts v.United States

Pamela R. Shisler

Full Article
Section members may also view this issue of The Tax Lawyer in its entirety .


Published by
Section of Taxation, American Bar Association
With the Assistance of
Georgetown University Law Center


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