Section of Taxation Publications
  VOL. 53
NO. 1
FALL 1999

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Business Purpose: The Assault Upon the Citadel
Robert Thornton Smith

Rethinking Deferential Review of Tax Court Decisions
David F. Shores

Why Can't We All Just Get Along: Finding Consistent Solutions to the Treatment of Derivatives and Other Problems
Willard B. Taylor
Diana L. Wollman

Publicly-Traded Partnerships and Unrelated Business Taxable Income
Johnny Rex Buckles

It's a Wonderful Life Insurance Policy: Determining the Correct Theory to Tax the Employee in Employer-Pay-All Equity Split-Dollar Life Insurance Arrangements
Jay Katz

Tax Evidence: A Primer on the Federal Rules of Evidence as Applied by the Tax Court
Joni Larson


Non-Payment of Taxes Without Exercise of Ordinary Business Care Justifies Tax Penalties: Fran Corp. v. United States

Wife's Elective Share Included in Gross Income under Section 662(a) as Distribution of Estate's DNI to Beneficiary: Brigham v. United States

Corporation Cannot Amortize Cost of Term Interests in Partnerships When Shareholders' Remainder Interests Are Funded by Extraordinary Distributions: CGF Industries v. Commissioner

Recalculations of Disability Retirement Benefits Based on Date of Hire Does Not Alter Section 104(a)(1) Tax Exemption Treatment: Picard v. Commissioner


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


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