Vol. 25 Nbr. 1, January 1994

Index

• Significant recent developments in estate planning.
• Insurance policy covering a promise to pay nonqualified deferred compensation did not trigger income.
• Promise to pay compensation secured by a letter of credit ruled currently taxable under sec. 83.
• Tax Court reversed in Idaho First National Bank.
• Historic absorption ratio provides easier administration of sec. 263A uniform cost capitalization.
• Proposed consolidated regulations pose trap for unwary.
• Overlooked RRA provision offers substantial tax deferral opportunity.
• Creating separate entities for business expansion will prevent current deduction of costs.
• Family limited partnership may be preferable to a family gift trust.
• Effect of lower compensation ceiling for employee retirement plans.
• Software acquired after August 10 generally will be subject to amortization over 36 months.
• Modifications to Sec. 956 made by the RRA.
• Donor power to remove trustee approved.
• Mark-to-market should not apply to small banks.
• Charitable contribution of S property.
• Preparation for Appeals Division conference.
• Sale of S stock by QSST.
• Asset acquisition for contingent convertible debt.
• Investment company mergers - corporations and partnerships compared.
• State income tax carryback refund claims usually are not accruable.
• Contrary to IRS opinion, land remediation expenses should be deductible.
• Investment interest expense and capital gain income.
• GRATs represent a significant opportunity, particularly for S shareholders.
• No taxable income limitation for excess investment interest expense carryover.
• IRS applies Sec. 162(k) to deemed stock redemption.
• Tax aspects of lobbying by public charities.
• Tax-deferred savings plans.
• Legal status of imaging systems and optical storage of records.
• Claiming the dependency exemption after a divorce.