Section Newsletters

Articles on Federal Taxation

Recently enacted legislation could adversely effect partnerships that sell property in exchange for an installment obligation By Edward J. Hannon Federal Taxation, April 2000 On December 17, 1999, President Clinton signed the Ticket to Work and Work Incentive Improvement Act of 1999 (the "1999 Act") into law.
Changes to the innocent spouse provisions: something old, something new By Carlos A. Saavedra Federal Taxation, February 2000 Code section 6013(d)(3) establishes joint and several liability for married taxpayers filing a joint income tax return. "Innocent Spouse" provisions refer to those Code provisions that create exceptions to this joint and several liability.
Individual income tax update By James S. Zmuda Federal Taxation, February 2000 The Internal Revenue Service ("IRS") has announced that for business travel after 1999, the optional mileage allowance for owned or leased vehicles will be 32.5 cents a mile.
Transfers to trust not included in gross estate Federal Taxation, February 2000 The Ninth Circuit has reversed a Tax Court decision and held that property transferred by a decedent was excludable from his gross estate pursuant to IRC 2036(a).
Individual income tax update By James S. Zmuda Federal Taxation, September 1999 Several requirements must be satisfied for divorce related payments to be treated as alimony, taxable to the payee and deductible by the payor.
Adequate disclosure on gift tax return to gain section 6501 statute of limitations protection By David R. Reid Federal Taxation, June 1999 For all gifts or nongifts (completed transfers of property) made after August 5, 1997, it is important that the gift tax return adequately discloses the gift in order for the taxpayer to be afforded section 6501 statute of limitation protection.
Corporate and partnership update By John B. Truskowski Federal Taxation, June 1999 When an employer files for bankruptcy, it may eventually be discharged from its obligations to remit taxes it withheld from wages paid to its employees.
Taxpayers making “voluntary” installment agreement payments cannot designate to which liabilities the payments will apply By James S. Zmuda Federal Taxation, June 1999 Opportunities to defer or reduce the collection of tax payments by the Internal Revenue Service ("IRS") include bankruptcy1 and offers in compromise.2 Another approach is the installment agreement.
Trade associations, associate members and unrelated business income By David R. Reid Federal Taxation, April 1999 Business Leagues, Chambers of Commerce, Real Estate Boards, Boards of Trade, or Professional Football Leagues not organized for profit and no part of the net earnings of which inures to the benefit of any private shareholders or individuals are exempt from federal income tax pursuant to IRC section 501(c)(6).
Corporate and partnership update By John B. Truskowski Federal Taxation, February 1999 In 330 W. Hubbard Restaurant Corporation, d/b/a Coco Pazzo v. United States, N.D. Ill. No. 98 C 178, District Court Judge Marvin Aspen held that a restaurant was liable for FICA taxes on unreported tips.
Federal income taxes in bankruptcy By John B. Truskowski Commercial Banking, Collections, and Bankruptcy, February 1999 How federal income taxes are handled in bankruptcy is unclear to most practitioners, including those concentrating in taxation, who do not practice in the bankruptcy area
Of FLPs and LLCs: Alternative estate freeze and asset protection techniques By James S. Zmuda Federal Taxation, February 1999 The estate planning world has become filled with acronyms, including: GRITs, GRATs, GRUTs, NIMCRUTs, QPRTs, FLPs and LLCs.

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