CUMULATIVE INDEX This index covers material in THE JOURNAL OF TAXATION, Volume 84, January-June 1996. Indexes are published twice annually, in June and December. ACCOUNTING Blizzard of Regulations: corporations, 84 JTAX 67, gation to avoid payroll tax liability, 84 JTAX 249, Advances and payments on loan guarantees were de- Feb96 Apr96 ductible despite IRS’s emphasis on taxpayer’s equity Excess loss account Regs. require taxpayers to take an INTERNATIONAL position, 84 JTAX 28, Jan96 earlier, determined approach to planning, by Douglas Final Regulations on conduit financing arrangements Are rotable spare parts properly treated as depreciable Reed Maughan, 84 JTAX 289, May96 empower the IRS, by Peter A. Glicklich, 84 JTAX 5, assets or inventory?, by W. Eugene Seago, 84 JTAX 347, Final consolidated group hedging Regulations permit Jan96 Jun96 retroactive elections, by Steven D. Conlon, Peter J. Cun- Blizzard of Regulations: international, 84 JTAX 68, Blizzard of Regulations: PALs, 84 JTAX 68, Feb96 nors, Suzanne M. Russell, and Charles W. Wheeler, 84 Feb96 Can an ordinary abandonment loss be taken on pub- JTAX 197, Apr96 Carefui planning may avoid reduction in foreign-source licly traded securities?, by Karl J. Bambas and Glen Final rules for gain or loss on stock of common parent, income under Section 863(b) Prop. Regs., by John P. Grider, 84 JTAX 80, Feb96 84 JTAX 195, Apr96 Kennedy and Stephen C. Fox, 84 JTAX 232, Apr96 Divided Tax Court applies INDOPCO to hostile Final 338 Regs. confirm separate treatment for majori- Final cost sharing Regulations: Do they solve the intan- takeovers, by Richard M. Lipton, 84 JTAX 21, Jan96 ty, minority shareholders, by Bryan P. Collins, C. Ellen gibles puzzle?, by William G. Dodge, Julie Joy, Edward Fifth Circuit joins others in rejecting “erroneous deduc- MacNeil, and Mark A. Schneider, 84 JTAX 169, Mar96 Maguire, and Alan Shapiro, 84 JTAX 270, May96 tion” exception to tax benefit rule, 84 JTAX 3, Jan96 Spinoffs of recently purchased businesses—what will General use rule for intangibles replaces “active con- Investor-guarantor denied bad debt loss on purchase of be the impact of a recent Tax Court decision?, by duct” standard, 84 JTAX 32, Jun96 property in bankruptcy,8 4 JTAX 28, Jan96 Robert Willens, 84 JTAX 32, Jan96 Internet sales pose international tax challenges, by Peter IRS considers new approaches to capitalization ques- Techniques abound for avoiding difficult continuity of A. Glicklich, Sanford H. Goldberg, and Howard J. tions,8 4 JTAX 132, Mar96 interest determinations, by Robert Willens, 84 JTAX Levine, 84 JTAX 325, Jun96 Just when will environmental clean-up expenditures be 342, Jun96 IRS catches up on Regulations projects in the foreign deductible?, by Richard M. Lipton, 84 JTAX 75, Feb96 ESTATES, TRUSTS, & GIFTS area,8 4 JTAX 195, Apr96 Mark-to-market rules apply to charitable contributions Benefits of special-use valuation enhanced by availabil- IRS issues broad revision of withholding rules for in- of long-term gains from futures contracts, 84 JTAX ity of minority discount in applying $750,000 cap, 84 come paid to foreigners, 84 JTAX 259, May96 NNoedb3A w5epy4ca r ,alR9 prea6iJerty usnan tl9A- t6.tlo o osK-rsneo iqwogunnhe strtc eo adncnetmdhrp aatcnLtieg oeen m- Geo.otf fh- Ksomnudiebg tshihwtdio,ilda lr 8yr4’pe seq JrucTmioAirnesXv s eimr2oot2nse5,td, GBleoJJinfTTze AAzrtXaXhare td 96i p17or,,on of-FFb seeRlkbbeei99gmp66usp l ianitgni otfnhisen :al P reRoseptgaosts.ee scd,u rteRr eugmssta.sn,, y b ayn( bdLu ltog yinfdot tsL ,ea vl8la4) NSoeeFbuwdeyr b cSu9Set6nu e dbvoepefrna rlotDps. rs iFeEo srrR d eaigrhnuslcl.,ue rse,r8a e4s bde JyT soAAonl Xmae sn t 1o7oLc4f.k, tFMhiiensac rhdf9lio,6fr f ei8ic4gu nl tJiaTefAsf Xilc irae1ta0et6s-,, debentures, 84 JTAX 83, Feb96 Plaine and Pam H. Schneider, 84 JTAX 203, Apr96 LETTER RULINGS Recent cases reflect continuing IRS uncertainties about Grandparents’ identical trusts for grandchildren, nam- Agent did not raise accounting method issue before COD income from contingent debt, by Martin B. Cow- ing each other as trustee, were not reciprocal, 84 JTAX taxpayer sought change, 84 JTAX 116, Feb96 an, 84 JTAX 261, May96 92, Feb96 B reorg. not disqualified by shareholder's transfer of ac- Retirement community operator had to report income Home sweeter home: reformation allowed for personal quiring stock to wholly owned corporation, 84 JTAX only as entry fees became nonrefundable, 84 JTAX residence trusts, 84 JTAX 260, May96 313, May96 353, Jun96 IRAs payable to QDOT are eligible for marital deduc- Basic operations exception to the NOL limitation anti- Uncollectible OID: To accrue or not to accrue?, by Mar- tion as QTIP, 84 JTAX 156, Mar96 stuffing rule, 84 JTAX 49, Jan96 tin D. Pollack, Stuart J. Goldring, and Larry J. Gelbfish, IRS revises security arrangements for payment of Benefit plan “controlled group” principles could be ex- 84 JTAX 157, Mar96 QDOT tax, by Douglas L. Siegier and Lloyd Leva panded by health-care IDS ruling, 84 JTAX 312, With planning, small real estate contractors can still use Plaine, 84 JTAX 13, Jan96 May96 the cash method of accounting, by W. Eugene Seago, IRS takes questionable new view of split-dollar life in- Company may correct reporting of reclassified worker's 84 JTAX 162, Mar96 surance arrangements, by Earl M. Colson, 84 JTAX pay, 84 JTAX 117, Feb96 358, Jun96 Contract termination payments were deductible as COMPENSATION & BENERTS Planning for the allocation of administration exp P 84 JTAX 184, Mar96 Audit guidelines cover plan distributions and Section to income under Hubert, by Scott H. Malin and Ben- Conversion of nonprofit entity to stock corporation 415 benefit limitations, 84 JTAX 147, Mar96 nett S. Keller, 84 JTAX 213, Apr96 qualifies as an E reorganization, 84 JTAX 117, Feb96 Blizzard of Regulations: compensation and benefits, 84 Refining the estate planning potential of the near-zero Corporate restructuring recharacterized by IRS, 84 JTAX 67, Feb96 CRUT technique, by Simon Levin, Jay A. Soled, and JTAX 183, Mar96 Despite participation in plans and withholding by em- Nathan E. Arnell, 84 JTAX 355, Jun96 Definition of banking business for foreign tax credit ployer, insurance agent could deduct expenses above Sale: of remainder failed to keep full value of stock out purposes may have wider applicability, 84 JTAX 372, the line, 84 JTAX 244, Apr96 of estate—pre-legislation freeze technique ineffective, Jun96 Ensuring deductions for performance-based compen- 84 JTAX 19, Jan96 Health benefits for employee's domestic partner taxable sation in excess of $1 million, by William L. Sollee, 84 Trusts as beneficiaries may prolong IRA distributions to employee, 84 JTAX 241, Apr96 JTAX 360, Jun9é and save taxes, by Leonard J. Witman and Laura Holder of incentive stock options exercised the [SOs Final Regs. on eligible rollover distributions from qual- Weyant-Kearney, 84 JTAX 86, Feb96 when he paid full exercise price, 84 JTAX 240, Apr96 ified plans, 84 JTAX 54, Jan96 Using a growth strategy for charitable remainder trust IRS disqualifies GRATs using notes to pay annuities, 84 14 new funding methods approved for defined benefit portfolios, by Laurence B. Siegel and Eric I. Swerdlin, JTAX 311, May96 plans, 84 JTAX 244, Apr96 84 JTAX 150, Mar96 IRS requires current inclusion of OID regardless of IRA assets not reachable by patients of accused, bank- Wife estopped by duty of consistency from increasing doubtful collectibility, 84 JTAX 51, Jan96 rupt MD, 84 JTAX 3, Jan96 husband’s basis in inherited property, 84 JTAX 18, Only one of three expense reimbursement arrange- Living with VCR and CAP—the ins and outs of the Jan96 ments was accountable plan, 84 TAX 115, Feb96 IRS’s remedial programs for employee plans, by C. Payments to another corporation for R&D activities Frederick Reish, Bruce L. Ashton, and David R. Levin, EXEMPT were not R&E expenditures, 84 JTAX 241, Apr96 84 JTAX 142, Mar96 Blizzard of Regulations: exempt organizations, 84 JTAX Post-reorganization liquidation of target may be struc- Once an employalewaeys, an employee—CA-1 imp 68, Feb96 tured as a statutory merger to avoid unfavorable re- duty of consistency on taxpayer, 84 JTAX 259, May96 Doing business as a cooperative in the face of increased cast, 84 JTAX 50, Jan96 Plan assets could not be used to obtain release of em- challenges from IRS, by Daniel S. Welytok, 84 JTAX 37, Prior remittance that exceeded estate tax due was pay- ployment-related claims, 84 JTAX 55, Jan96 Jan96 ment, not deposit, 84 JTAX 371, Jun96 Retroactive indefinite extension and some changes in Hospital's self-insurance fund was not exempt service Providing bar and catering services not fatal to 501(c) CAP for plans with assets held by troubled insurers, organization, 84 JTAX 246, Apr96 org. or its parent, 84 JTAX 373, Jun96 84 JTAX 147, Mar96 Municipal bonds cannot be bifurcated into loan and QTIP and non-QTIP property aggregated in determin- Temp. Regs. ease required notifications to qualified plan subsidy components to avoid private activity bond ing value of decedent's estate, 84 JTAX 372 participants, 84 JTAX 55, jan96 threshold, 84 JTAX 246, Apr96 Redemption of closely held stock following distribution CORPORATIONS, SHAREHOLDERS FRAUD & NEGLIGENCE from trust was not a dividend, 84 JTAX 372, Jun96 AllocE&aP itn ais pninogff inl ight oft he latest consol- IRS need not use John Doe summons to enforce cash- Redemption of estate's preferred stock treated as a dis- idateed e reporting form, CA-9 says, 84 JTAX 249, Apr96 tribution, 84 JTAX 185, Mar96 69, Lender’s due diligence does not require outside investi- Relocation company’s purchase of employee home did JOURNAL OF TAXATION @ JUNE 1996 CUMULATIVE INDEX This index covers material in THE JOURNAL OF TAXATION, Volume 84, January-June 1996. Indexes are published twice annually, in June and December. ACCOUNTING Blizzard of Regulations: corporations, 84 JTAX 67, gation to avoid payroll tax liability, 84 JTAX 249, Advances and payments on loan guarantees were de- Feb96 Apr96 ductible despite IRS’s emphasis on taxpayer’s equity Excess loss account Regs. require taxpayers to take an INTERNATIONAL position, 84 JTAX 28, Jan96 earlier, determined approach to planning, by Douglas Final Regulations on conduit financing arrangements Are rotable spare parts properly treated as depreciable Reed Maughan, 84 JTAX 289, May96 empower the IRS, by Peter A. Glicklich, 84 JTAX 5, assets or inventory?, by W. Eugene Seago, 84 JTAX 347, Final consolidated group hedging Regulations permit Jan96 Jun96 retroactive elections, by Steven D. Conlon, Peter J. Cun- Blizzard of Regulations: international, 84 JTAX 68, Blizzard of Regulations: PALs, 84 JTAX 68, Feb96 nors, Suzanne M. Russell, and Charles W. Wheeler, 84 Feb96 Can an ordinary abandonment loss be taken on pub- JTAX 197, Apr96 Carefui planning may avoid reduction in foreign-source licly traded securities?, by Karl J. Bambas and Glen Final rules for gain or loss on stock of common parent, income under Section 863(b) Prop. Regs., by John P. Grider, 84 JTAX 80, Feb96 84 JTAX 195, Apr96 Kennedy and Stephen C. Fox, 84 JTAX 232, Apr96 Divided Tax Court applies INDOPCO to hostile Final 338 Regs. confirm separate treatment for majori- Final cost sharing Regulations: Do they solve the intan- takeovers, by Richard M. Lipton, 84 JTAX 21, Jan96 ty, minority shareholders, by Bryan P. Collins, C. Ellen gibles puzzle?, by William G. Dodge, Julie Joy, Edward Fifth Circuit joins others in rejecting “erroneous deduc- MacNeil, and Mark A. Schneider, 84 JTAX 169, Mar96 Maguire, and Alan Shapiro, 84 JTAX 270, May96 tion” exception to tax benefit rule, 84 JTAX 3, Jan96 Spinoffs of recently purchased businesses—what will General use rule for intangibles replaces “active con- Investor-guarantor denied bad debt loss on purchase of be the impact of a recent Tax Court decision?, by duct” standard, 84 JTAX 32, Jun96 property in bankruptcy,8 4 JTAX 28, Jan96 Robert Willens, 84 JTAX 32, Jan96 Internet sales pose international tax challenges, by Peter IRS considers new approaches to capitalization ques- Techniques abound for avoiding difficult continuity of A. Glicklich, Sanford H. Goldberg, and Howard J. tions,8 4 JTAX 132, Mar96 interest determinations, by Robert Willens, 84 JTAX Levine, 84 JTAX 325, Jun96 Just when will environmental clean-up expenditures be 342, Jun96 IRS catches up on Regulations projects in the foreign deductible?, by Richard M. Lipton, 84 JTAX 75, Feb96 ESTATES, TRUSTS, & GIFTS area,8 4 JTAX 195, Apr96 Mark-to-market rules apply to charitable contributions Benefits of special-use valuation enhanced by availabil- IRS issues broad revision of withholding rules for in- of long-term gains from futures contracts, 84 JTAX ity of minority discount in applying $750,000 cap, 84 come paid to foreigners, 84 JTAX 259, May96 NNoedb3A w5epy4ca r ,alR9 prea6iJerty usnan tl9A- t6.tlo o osK-rsneo iqwogunnhe strtc eo adncnetmdhrp aatcnLtieg oeen m- Geo.otf fh- Ksomnudiebg tshihwtdio,ilda lr 8yr4’pe seq JrucTmioAirnesXv s eimr2oot2nse5,td, GBleoJJinfTTze AAzrtXaXhare td 96i p17or,,on of-FFb seeRlkbbeei99gmp66usp l ianitgni otfnhisen :al P reRoseptgaosts.ee scd,u rteRr eugmssta.sn,, y b ayn( bdLu ltog yinfdot tsL ,ea vl8la4) NSoeeFbuwdeyr b cSu9Set6nu e dbvoepefrna rlotDps. rs iFeEo srrR d eaigrhnuslcl.,ue rse,r8a e4s bde JyT soAAonl Xmae sn t 1o7oLc4f.k, tFMhiiensac rhdf9lio,6fr f ei8ic4gu nl tJiaTefAsf Xilc irae1ta0et6s-,, debentures, 84 JTAX 83, Feb96 Plaine and Pam H. Schneider, 84 JTAX 203, Apr96 LETTER RULINGS Recent cases reflect continuing IRS uncertainties about Grandparents’ identical trusts for grandchildren, nam- Agent did not raise accounting method issue before COD income from contingent debt, by Martin B. Cow- ing each other as trustee, were not reciprocal, 84 JTAX taxpayer sought change, 84 JTAX 116, Feb96 an, 84 JTAX 261, May96 92, Feb96 B reorg. not disqualified by shareholder's transfer of ac- Retirement community operator had to report income Home sweeter home: reformation allowed for personal quiring stock to wholly owned corporation, 84 JTAX only as entry fees became nonrefundable, 84 JTAX residence trusts, 84 JTAX 260, May96 313, May96 353, Jun96 IRAs payable to QDOT are eligible for marital deduc- Basic operations exception to the NOL limitation anti- Uncollectible OID: To accrue or not to accrue?, by Mar- tion as QTIP, 84 JTAX 156, Mar96 stuffing rule, 84 JTAX 49, Jan96 tin D. Pollack, Stuart J. Goldring, and Larry J. Gelbfish, IRS revises security arrangements for payment of Benefit plan “controlled group” principles could be ex- 84 JTAX 157, Mar96 QDOT tax, by Douglas L. Siegier and Lloyd Leva panded by health-care IDS ruling, 84 JTAX 312, With planning, small real estate contractors can still use Plaine, 84 JTAX 13, Jan96 May96 the cash method of accounting, by W. Eugene Seago, IRS takes questionable new view of split-dollar life in- Company may correct reporting of reclassified worker's 84 JTAX 162, Mar96 surance arrangements, by Earl M. Colson, 84 JTAX pay, 84 JTAX 117, Feb96 358, Jun96 Contract termination payments were deductible as COMPENSATION & BENERTS Planning for the allocation of administration exp P 84 JTAX 184, Mar96 Audit guidelines cover plan distributions and Section to income under Hubert, by Scott H. Malin and Ben- Conversion of nonprofit entity to stock corporation 415 benefit limitations, 84 JTAX 147, Mar96 nett S. Keller, 84 JTAX 213, Apr96 qualifies as an E reorganization, 84 JTAX 117, Feb96 Blizzard of Regulations: compensation and benefits, 84 Refining the estate planning potential of the near-zero Corporate restructuring recharacterized by IRS, 84 JTAX 67, Feb96 CRUT technique, by Simon Levin, Jay A. Soled, and JTAX 183, Mar96 Despite participation in plans and withholding by em- Nathan E. Arnell, 84 JTAX 355, Jun96 Definition of banking business for foreign tax credit ployer, insurance agent could deduct expenses above Sale: of remainder failed to keep full value of stock out purposes may have wider applicability, 84 JTAX 372, the line, 84 JTAX 244, Apr96 of estate—pre-legislation freeze technique ineffective, Jun96 Ensuring deductions for performance-based compen- 84 JTAX 19, Jan96 Health benefits for employee's domestic partner taxable sation in excess of $1 million, by William L. Sollee, 84 Trusts as beneficiaries may prolong IRA distributions to employee, 84 JTAX 241, Apr96 JTAX 360, Jun9é and save taxes, by Leonard J. Witman and Laura Holder of incentive stock options exercised the [SOs Final Regs. on eligible rollover distributions from qual- Weyant-Kearney, 84 JTAX 86, Feb96 when he paid full exercise price, 84 JTAX 240, Apr96 ified plans, 84 JTAX 54, Jan96 Using a growth strategy for charitable remainder trust IRS disqualifies GRATs using notes to pay annuities, 84 14 new funding methods approved for defined benefit portfolios, by Laurence B. Siegel and Eric I. Swerdlin, JTAX 311, May96 plans, 84 JTAX 244, Apr96 84 JTAX 150, Mar96 IRS requires current inclusion of OID regardless of IRA assets not reachable by patients of accused, bank- Wife estopped by duty of consistency from increasing doubtful collectibility, 84 JTAX 51, Jan96 rupt MD, 84 JTAX 3, Jan96 husband’s basis in inherited property, 84 JTAX 18, Only one of three expense reimbursement arrange- Living with VCR and CAP—the ins and outs of the Jan96 ments was accountable plan, 84 TAX 115, Feb96 IRS’s remedial programs for employee plans, by C. Payments to another corporation for R&D activities Frederick Reish, Bruce L. Ashton, and David R. Levin, EXEMPT were not R&E expenditures, 84 JTAX 241, Apr96 84 JTAX 142, Mar96 Blizzard of Regulations: exempt organizations, 84 JTAX Post-reorganization liquidation of target may be struc- Once an employalewaeys, an employee—CA-1 imp 68, Feb96 tured as a statutory merger to avoid unfavorable re- duty of consistency on taxpayer, 84 JTAX 259, May96 Doing business as a cooperative in the face of increased cast, 84 JTAX 50, Jan96 Plan assets could not be used to obtain release of em- challenges from IRS, by Daniel S. Welytok, 84 JTAX 37, Prior remittance that exceeded estate tax due was pay- ployment-related claims, 84 JTAX 55, Jan96 Jan96 ment, not deposit, 84 JTAX 371, Jun96 Retroactive indefinite extension and some changes in Hospital's self-insurance fund was not exempt service Providing bar and catering services not fatal to 501(c) CAP for plans with assets held by troubled insurers, organization, 84 JTAX 246, Apr96 org. or its parent, 84 JTAX 373, Jun96 84 JTAX 147, Mar96 Municipal bonds cannot be bifurcated into loan and QTIP and non-QTIP property aggregated in determin- Temp. Regs. ease required notifications to qualified plan subsidy components to avoid private activity bond ing value of decedent's estate, 84 JTAX 372 participants, 84 JTAX 55, jan96 threshold, 84 JTAX 246, Apr96 Redemption of closely held stock following distribution CORPORATIONS, SHAREHOLDERS FRAUD & NEGLIGENCE from trust was not a dividend, 84 JTAX 372, Jun96 AllocE&aP itn ais pninogff inl ight oft he latest consol- IRS need not use John Doe summons to enforce cash- Redemption of estate's preferred stock treated as a dis- idateed e reporting form, CA-9 says, 84 JTAX 249, Apr96 tribution, 84 JTAX 185, Mar96 69, Lender’s due diligence does not require outside investi- Relocation company’s purchase of employee home did JOURNAL OF TAXATION @ JUNE 1996 CUMULATIVE INDEX not give rise to compensation, 84 JTAX 184, Mar96 around third-party recordkeeper rules, 84 [TAX STATE & LOCAL Retained purchase credits were income, not an exclud- State “source” taxation of retirement benefits-—what's able rebate,8 4J TAX 184, Mar96 How equitable recoupment is applied may depend barred, what's left, by Douglas L. Lindholm, Mary B. S corporation rules apply to nonqualifying redemption who asseitr, 8t4 JsTA X 121, Feb96 distribution, 84 JTAX 311, May96 IRS errors not correctable by mitigation absent a Hevener, and Carolyn Kelley, 84 JTAX 299, May96 Seller of motor vehicle service agreements held to be termination”,8 4 JTAX 251, Apr96 States may no longer tax some pension income of for- insurance company, 84 JTAX 242, Apr96 IRS willingt ot ry mediation in docketed Tax Court mer residents,8 4 JTAX 131, Mar96 Shaamreenhdomldeenrt atop psrtoovcak l optnoito n plraenq,u i8r4ed JTfoArX 371,e mpJluonye9r6' s Laetse ,f8 i4leJ rTs AmXa y1 8w6a,n tM arto9 6a void Tax Court after Suprer 1€ AUTHOR INDEX Sliding scale depreciation not acceptable method for Court's refund opinion, 84 JTAX 131, Mar% Nathan E. Arnell TV film rights, 84 JTAX 239, Apr96 New stuff coming to the FOIA reading room Bruce L. Ashton Stock could be transferred to qualified personal resi- vice advice memos to be released, 84 [TAX Karl J. Bambas dence trust, 84 JTAX 52, Jan96 No appellate revieowf jeopardy assessment des Robert L. Bean Stock plan cancellation payments are deductible costs trict court's failure to rule within 20 days, 84 JTA® in acquisition, 84 JTAX 53, Jan96 Jan96 Suspended S corporation losses are not transferable, 84 Refund claims and forum selection after Lund) Bryan P. Collins JTAX 184, Mar96 delinquent taxpayers beware!, by L. Paige Marve Earl M. Colson Taxability of member assessments collected by time- JTAX 303, May96 share condominium management association, 84 6001:A space saving odyssey, 84 JTAX 132, Mar Peter j. Connors JTAX 52, Jan96 Supreme Court, Ninth Circuit decide tax-related Martin B. Cowan Texas banking entity held to constitute a corporation tions in bankruptcy cases, 84 JTAX 324, Jun j.D. Dell per se, 84 JTAX 183, Mar96 Tax Court continues its broad interpretatior Transfer of remainder interest in residence allowed as a feree liability, 84 JTAX 186, Mar96 William G. Dodge charitable contribution, 84 JTAX 52, Jan96 To be safe in Sixth Circuit, taxpayers must use cert Steven D. Erdahl Trust company held ineligible to elect Subchapter S sta- or registered mail to IRS,8 4 JTAX 309, May 96 Alan L. Fischl tus, 84 JTAX 314, May96 Unrealized gain is not included in “acquisitior Stephen C. Fox PARTNERSHIPS, S CORPORATIONS, & LLCs determining eligibility for award of litigation Michael G. Frankel Blizzard of Regulations: pass-through entities, 84 JTAX JTAX 252, Apr96 Larry J. Gelbfish 67, Feb96 REAL ESTATE Peter A. Glicklich Final PTP Regs. abandon restrictive conditions and Leasehold improvements held eligible for ten-year de adopt workable new exemptions, by Richard M. Lip- preciation, 84 JTAX 119, Feb96 Sanford H. Goldberg ton, Leslie H. Loffman, and Sanford C. Presant, 84 Occupancy rate irrelevant in determining fair renta Stuart J. Goldring JTAX 279, May96 value of vacation condo, 84 JTAX 376, Jun96 Glen Grider Final Section 1361 Regulations clarify definition of S Payment for cancellation of lease capitalized corporation, by Jordan P. Rose and Michael G. Schin- found it part of overall pian to acquire other rea Julie Joy ner, 84 JTAX 44, Jan96 property,8 4 JTAX 376, Jun96 Bennett S. Keller IRS changes “readily tradable on secondary market” test Safe harbor for low-income housing exempt orgar in final PTP Regs., 84 JTAX 3, Jan96 tions finalized, 84 JTAX 375, Jun96 Carolyn Kelley IRS implements “check-the-box”—Prop. Regs. include John P. Kennedy SHOP TALK single-owner entities, 84 JTAX 323, Jun96 Ray A. Knight Another issue for partnerships of grantor tr Partner's filing of amended return was subject to uni- JTAX 64, Jan96 Lee G. Knight fied audit procedures, 84 JTAX 196, Apr96 “Booking up” for partnership profits interests, 84 [TAX john L. Kramer Prop. Regs. change deemed distribution rules in part- 62, Jan96 David R. Levin nership termination on sale or exchange, 84 JTAX 324, Jun96 Courts can’t agree on when negligence penalty applies Simon Levin 731(c) Prop. Regs. on distributions of marketable secu- 84 JTAX 191, Mar96 Howard J. Levine rities provide a measure of clarity, by j.D. Dell, Drafting LLC, partnership agreements pending “che k Douglas L. Lindholm MJiucnh9a6e l G. Frankel, and Roger F. Pillow, 84 JTAX 332, Extohteic- bocaxr,s” 8 a4rJ eT AbXe i2n5g 4,s oAlpd r9n6or th of the border Richard M. Lipton Special provisions for distributions and basis affect re- whom?,8 4 JTAX 191, Mar96 Leslie H. Loffman demptions by S corporations, by John L. Kramer and Findinga silver lining in a negative ruling from IR C. Ellen MacNeil Ronald S. Ross, 84 JTAX 133, Mar96 JTAX 381, Jun96 Edward Maguire PERSONAL GAfeOe s, r8e4p orJtTsA Xa d2e55c,l iAnep r9in6 Service's payout of attorne Scott H. Malin Deducting legal costs of defending against claims of How to handle partnership Section 1031 exchange: L. Paige Marvel sexual harassment in the workplace, by David R. Bren- with boot, 34 JTAX 255, Apr96 Douglas Reed Maughan nan and Susan L. Megaard, 84 JTAX 94, Feb96 IRS all90o% dwiscsoun t on assignee interests in fan Susan L. Megaard Divided Tax Court allows deduction of interest on tax partnerships,8 4 JTAX 319, May96 Roger F. Pillow arising from a trade or business, by Richard M. Lipton, IRS guidelines on audits of pizza joints: food for Lloyd Leva Plaine 84 JTAX 218, Apr96 thought...While beer spillage is making the Ser) Interest income not exempt where debt was arbitrage foam, 84 JTAX 380-81, Jun96 Martin D. Pollack bonds and issuer failed to pay differential to U.S., 84 LLC rulings put gloss on status, accounting method is Sanford C. Presant JTAX 102, Feb96 sues,8 4J TAX 316, May96 C. Frederick Reish Per diem allowance and optional method for business More on “booking up” for partnership profits interests Jordan P. Rose travel expenses updated, 84 JTAX 196, Apr96 84 JTAX 191, Mar96 Ronald S. Ross Sehcotlidoinn g6 6t7a2x lpieabniallittyy iiss, 8n4o t JTdAedXu c1t0i3b,l eF ebb9u6t state with- Mobroxe. ”o n8 4 dJraTfAtXi ng32 0L,L CM aayg9r6e ements pending “check Suzanne M. Russell Tax Court says interest on business-related tax deficien- More on unfriendly Regulations from Treasur Michael G. Schinner cies is deductible, 84 JTAX 132, Mar96 JTAX 379, Jun96 Mark A. Schneider PROCEDURE Section 644 and nongrantor charitable lead trust Pam H. Schneider Attorney's deliberate attempt to mislead IRS as to ter- JTAX 64, Jan96 W. Eugene Seago mination of S/L extension was ineffective, 84 JTAX Tax Court gives TRA '86 Blue Book “lesser respe Alan Shapiro 252, Apr96 JTAX 190, Mar96 Laurence B. Siegel Blizzard of Regulations: procedural matters, 84 JTAX Tax planfnori dinvogrce d Nobel Prize winners, 84 TA) Douglas L. Siegler 68, Feb96 127, Feb96 CA-5 finds propriety of disclosure of return informa- Tax whipsaw on settlement of employment lawsuit, 84 tion does not depend on validity of underlying levy, JTAX 256, Apr96 84 JTAX 122, Feb96 1031 excnhot aaffecnted gby ewithsdraw al of decisio Circuits split on whether equitable tolling applies to re- on loan offsets,8 4 JTAX 379, Jun96 Daniel S. Welytok fund claims, 84 JTAX 58, Jan96 Treasury warns of less-friendly final Regulations, 84 Laura Weyant-Kearney Debtor could claim unscheduled refund related to JTAX 126, Feb96 asset abandoned by trustee,8 4 JTAX 122, Update on IRS's closing program for employee plans Charles W. Wheeler Feb96 other forms of correction may be available, 84 [TA» Robert Willens ... General summons power can’t be used for end run 319, May96 Leonard J. Witman JOURNAL OF TAXATION & JUNE 1996