1991

TOPICS:

All articles written by Robert W. Wood (unless otherwise noted)

 

 

MERGERS AND ACQUISITIONS

 

Shareholder Loan Guarantee Problems — One More Time!, Vol. 7, No. 15, S Corporations Tax Bulletin, S Corporations (December 19, 1991), p. 6.

S Corporations Holding Installment Notes, Vol. 7, No. 15, S Corporations Tax Bulletin, S Corporations (December 19, 1991), p. 5.

Subchapter S Simplification Still Hands in the Balance, Vol. 7, No. 15, S Corporations Tax Bulletin, S Corporations (December 19, 1991), p. 4.

S Corporation Distributions and Proposed Tax Simplification Changes, Vol. 7, No. 15, S Corporations Tax Bulletin, S Corporations (December 19, 1991), p. 3.

S Corporation Shareholder Guarantees: Know the Rules, Vol. 7, No. 15, S Corporations Tax Bulletin, S Corporations (December 19, 1991), p. 2.

Do Hidden Traps Remain In the One-Class-of-Stock Regulations?, Vol. 7, No. 15, S Corporations Tax Bulletin, S Corporations (December 19, 1991), p. 1.

S Corporation Shareholder Guarantees, Vol. 9, No. 12, Real Estate Digest (December 1991), p. 277.

Section 269 No Equal to Animal Farm, Vol 2, No. 8, Taxation of Mergers & Acquisitions (December 1991), p. 7.

More COD Problems, Vol 2, No. 8, Taxation of Mergers & Acquisitions (December 1991), p. 6.

Centre for Int’l Understanding Shows Misunderstanding of Section 337, Vol 2, No. 8, Taxation of Mergers & Acquisitions (December 1991), p. 6.

Campbell Decision May Impact LBO Funds, Vol 2, No. 8, Taxation of Mergers & Acquisitions (December 1991), p. 5.

Depreciating of Customer Lists Nixed, Vol 2, No. 8, Taxation of Mergers & Acquisitions (December 1991), p. 3.

New, Improved One-Class-of-Stock Regs, Vol 2, No. 8, Taxation of Mergers & Acquisitions (December 1991), p. 1.

Happy Ending in Disney Strikes Blow to Step-Transaction Doctrine, Vol. 4, No. 4, Corporate Taxation (November/December 1991), p. 55.

G Reorganizations Offer Planning Possibilities, Vol. 4, No. 4, Corporate Taxation (November/December 1991), p. 37.

Who Is Taxable When QSST Sells S Corporation Stock, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 1.

Failure to Withhold and Pay Employment Taxes: Another “Responsible Person” Victory, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 5.

Real Estate S Corporations Worth Looking Into, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 5.

Section 179 Deduction and S Limitations Unclear, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 4.

S Corporation Division Can Pass Muster, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 2.

Shareholder Guarantees: The Saga Continues, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 2.

Pension Reversions as Built-in Gains, Vol. 7, No. 14, S Corporations Tax Bulletin, S Corporations (November 21, 1991), p. 1.

Subissue Reorganization Rulings May Be Requested, Vol. 2, No. 7, Taxation of Mergers & Acquisitions (November 1991), p. 7.

Amortization of a Work Place, Vol. 2, No. 7, Taxation of Mergers & Acquisitions (November 1991), p. 7.

Proposed Section 382 Regs. Address NOLs, Vol. 2, No. 7, Taxation of Mergers & Acquisitions (November 1991), p. 2.

Final Loss Disallowance Regs. Offer Little Relief, Vol. 2, No. 7, Taxation of Mergers & Acquisitions (November 1991), p. 1.

Revised One-Class-of-Stock Regulations Offer Improvements, S Corporations (October 17, 1991), p. 4271.

Consolidated Note Did Not Increase S Shareholder’s Basis, Vol. 7, No. 13, S Corporations Tax Bulletin, S Corporations (October 17, 1991), p. 6.

Tax Simplification Bill S Provisions Still Touted Despite New One-Class-of-Stock Regulations, Vol. 7, No. 13, S Corporations Tax Bulletin, S Corporations (October 17, 1991), p. 5.

Statute of Limitations: The Controversy Continues, Vol. 7, No. 13, S Corporations Tax Bulletin, S Corporations (October 17, 1991), p. 5.

Another Tax Court Decision on Jurisdiction Over S Corporation Items, Vol. 7, No. 13, S Corporations Tax Bulletin, S Corporations (October 17, 1991), p. 2.

Even the New One-Class-of-Stock Rules Face Criticism, Vol. 7, No. 13, S Corporations Tax Bulletin, S Corporations (October 17, 1991), p. 1.

More on Earnings Strippings, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 7.

Consolidated Return Proposed Regs. on Stock Redemption, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 7.

Transitional Relief for Losses by Consolidated Groups, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 6.

Pension Guarantees Raise Tax Issues, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 5.

Excise Tax on Partnership Roll-ups Proposed, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 3.

Walt Disney Negates Step-Transaction Doctrine, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 2.

Intangible Writeoff May Be Allowed, Vol. 2, No. 6, Taxation of Mergers & Acquisitions (October 1991), p. 1.

Putting the “Mail” into Greenmail, Vol. 4, No. 3, Corporate Taxation (September/October 1991), p. 55.

No Section 1244 Stock Deduction For S Shareholders, Vol. 7, No. 12, S Corporations Tax Bulletin, S Corporations (September 19, 1991), p. 6.

Undistributed S Corporation Income Taxable, Vol. 7, No. 12, S Corporations Tax Bulletin, S Corporations (September 19, 1991), p. 5.

Bill Would Allow S Corporations To Subdivide Property, Vol. 7, No. 12, S Corporations Tax Bulletin, S Corporations (September 19, 1991), p. 5.

The Tax Simplification Act From the AAA Perspective, Vol. 7, No. 12, S Corporations Tax Bulletin, S Corporations (September 19, 1991), p. 4.

S Corporation Tax Matters Person Held Liable for Penalty, Vol. 7, No. 12, S Corporations Tax Bulletin, S Corporations (September 19, 1991), p. 2.

Revised One-Class-of-Stock Rules Issued Under Section 1361, Vol. 7, No. 12, S Corporations Tax Bulletin, S Corporations (September 19, 1991), p. 1.

Charting a Course Through the NOL Rules, Vol. 2, No. 5, Taxation of Mergers & Acquisitions (September 1991), p. 7.

When is a Section 335 Liquidation Complete?, Vol. 2, No. 5, Taxation of Mergers & Acquisitions (September 1991), p. 7.

More on the Tax Benefit Rule, Vol. 2, No. 5, Taxation of Mergers & Acquisitions (September 1991), p. 6.

Recent Trends and Transactions, Vol. 4, PLI Tax Strategies for Corporate Acquisitions, Dispositions, Financings, Joint Ventures, Reorganizations, and Restructurings 1991 Program (August 26, 1991), p. 251.

Tax Court Has No Jurisdiction to Determine Shareholder’s Basis in S Stock, Vol. 7, No. 11, S Corporations Tax Bulletin, S Corporations (August 15, 1991), p. 5.

More Statute of Limitations Squabbles, Vol. 7, No. 11, S Corporations Tax Bulletin, S Corporations (August 15, 1991), p. 4.

Estate Freezes of S Corporation Stock: Planning the Big Chill, Vol. 7, No. 11, S Corporations Tax Bulletin, S Corporations (August 15, 1991), p. 1.

Lessons From the PC Era, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 8.

Section 382 Limits May Be Invoked in NCNB Acquisition of C&S/Sovran, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 8.

Deconsolidation Deadline Extended, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 8.

Proposed Greenmail Regs. Impose Reporting Requirements, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 7.

Rights Plans Still in the News, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 6.

Azar Says “Nuts” to Anti-Capital Asset Theory, But Not in Circle K Stores, by Robert W. Wood and Robert Willens, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 3.

Fisher-Price Spinoff Update, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 2.

Earnings-Stripping Rules Offer Safe Harbor, Vol. 2, No. 4, Taxation of Mergers & Acquisitions (August 1991), p. 1.

Some Like-Kind Exchange Restrictions Eased in Final Rules, Vol. 4, No. 2, Corporate Taxation (July/August 1991), p. 34.

Watch Out for Restricted Stock Purchases, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 5.

Inadvertent Terminations: IRS Is Forgiving, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 5.

More on Statute of Limitations, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 4.

IRS Rules on Passive Investment Income Inquiries, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 4.

S Corporation Conference Highlights, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 2.

Tax Court Denis Small S Corporation Exemption From Unified Audit Rules, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 1.

Mortgage Swap Losses Held Deductible, Vol. 2, No. 3, Taxation of Mergers & Acquisitions (July 1991), p. 8.

High Court to Launder National Starch, Vol. 2, No. 3, Taxation of Mergers & Acquisitions (July 1991), p. 7.

Disguised Sale Partnership Rules Affect Corporate Structures, Vol. 2, No. 3, Taxation of Mergers & Acquisitions (July 1991), p. 6.

More Final Section 1031 Regulations Issued, Vol. 2, No. 3, Taxation of Mergers & Acquisitions (July 1991), p. 2.

Virginia S Corporations, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 6.

Hawaii Adds Estimated Tax Requirements, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 7.

California: Monitoring State S Election Requirements; Bill Would Modify Material Participation Rules, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 6.

Bill Would Allow S Corporation ESOPs, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 6.

Potential Legislative Relief to One-Class-of-Stock Rules, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 6.

Reincorporation in Another State Is An F Reorganization; Election Undisturbed, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 5.

S Corporation May Spread Change of Tax Year Effect Over Four Years, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 5.

C to S Conversion Checklist, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 3.

Section 1374 Repeal No Longer on Horizon, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 2.

S Corporation Income Was Taxable to Ex-Wife Even Though She Didn’t Receive It, Vol. 7, No. 9, S Corporations Tax Bulletin, S Corporations (June 20, 1991), p. 1.

Authority of Letter Rulings, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 8.

Holding Company Consideration for Foreign Buyers, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 8.

S Election Eligibility and Section 355, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 7.

Partnership Splitups Revisited, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 6.

New Coding Systems Adopted for Section 1031 Exchange, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 5.

Philip Morris Court Rejects Residual Method in Control Premium Case, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 3.

Section 269 No Real Threat?, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 3.

TAM Allows Exclusion of Short S Year From NOL Carryover, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 2.

Related-Party Debt Produces COD Income, Vol. 2, No. 2, Taxation of Mergers & Acquisitions (June 1991), p. 1.

Advance Rulings on Transfer Pricing Agreements Now Available, Vol. 4, No. 1, Corporate Taxation (May/June 1991), p. 37.

Buy-Sell Agreement Updated, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 7.

Sinking Fund Redemption Creates Corporate-Level Gain, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 7.

One-Class-of-Stock Bill Introduced, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 6.

Tech Advice Allows Termination Election Extension, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 6.

Inadvertent vs. Invalid: One-Class-of-Stock Horror, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 6.

New Jersey, New York Interpret S Rules, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 6.

Merger of Subsidiaries Did Not Invalidate Parent’s S Election, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 5.

Federal S and State C Status Possible, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 4.

Short S Year May Be Excluded From NOL Carryover, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 3.

Statute of Limitations: IRS Balks at S-Level Application; Tax Court Decides Another Case, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 2.

Revocable Trusts As S Shareholders: Hidden Traps, Vol. 7, No. 8, S Corporations Tax Bulletin, S Corporations (May 16, 1991), p. 1.

Designating the TMP, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 6.

Loan Guarantees: No Basis Increase, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 5.

S Corporation to Partnership Conversions, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 5.

Complying With Election Requirements For Distributing C Corporation E&P, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 4.

The Problem of the Ineligible Spouse Shareholder, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 4.

C to S Net Operating Loss Carryover Disallowed, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 2.

Inadvertent Termination of S Status: Can You Fix It Yourself?, Vol. 7, No. 7, S Corporations Tax Bulletin, S Corporations (April 18, 1991), p. 1.

Drexel Hit With $5.28 Billion Tax Claim, Vol. 1, No. 12, Taxation of Mergers & Acquisitions (April 1991), p. 6.

Solutions to the COD Quandary, Vol. 1, No. 12, Taxation of Mergers & Acquisitions (April 1991), p. 5.

Deconsolidation Procedures Announced, Vol. 1, No. 12, Taxation of Mergers & Acquisitions (April 1991), p. 6.

Proposed Regs on Acquisitions and Bankruptcy Reorganizations Jeopardize NOLs, Vol. 3, No. 6, Corporate Taxation (March/April 1991), p. 40.

Foreign Subsidiaries: Lettering Down the Bars?, Vol. 7, No. 6, S Corporations Tax Bulletin, S Corporations (March 21, 1991), p. 4.

No Carryback to S Years, Vol. 7, No. 6, S Corporations Tax Bulletin, S Corporations (March 21, 1991), p. 3.

Shareholder’s Consent to Extend Statute Also Applies to Corporation, Vol. 7, No. 6, S Corporations Tax Bulletin, S Corporations (March 21, 1991), p. 3.

One-Class-of-Stock Regulations May Be Revised, Vol. 7, No. 6, S Corporations Tax Bulletin, S Corporations (March 21, 1991), p. 2.

S Elections and Section 355, Vol. 7, No. 6, S Corporations Tax Bulletin, S Corporations (March 21, 1991), p. 1.

More on Section 269 Tax Avoidance and Bankruptcy Reorgs, Vol. 1, No. 11, Taxation of Mergers & Acquisitions (March 1991), p. 3.

Spin Followed By LBO, Vol. 1, No. 11, Taxation of Mergers & Acquisitions (March 1991), p. 5.

Proposed Regs Outline Stock-for-Debt Exception, Vol. 1, No. 11, Taxation of Mergers & Acquisitions (March 1991), p. 7.

Another “Responsible Person” Victory for Director/Officer, Vol. 7, No. 5, S Corporations Tax Bulletin, S Corporations (February 22, 1991), p. 7.

Revisiting S Corporation Estate Freezes After Section 2036(c) Repeal, Vol. 7, No. 5, S Corporations Tax Bulletin, S Corporations (February 22, 1991), p. 5.

IRS Releases Two Procedural Announcements, Vol. 7, No. 5, S Corporations Tax Bulletin, S Corporations (February 22, 1991), p. 5.

Suspended Losses Disappear on Death of Shareholder, Vol. 7, No. 5, S Corporations Tax Bulletin, S Corporations (February 22, 1991), p. 3.

Comments Continue on One-Class-of-Stock Regs, Vol. 7, No. 5, S Corporations Tax Bulletin, S Corporations (February 22, 1991), p. 2.

S Corporations Having Fewer Than 11 Shareholders Escape Unified Audit, Vol. 7, No. 5, S Corporations Tax Bulletin, S Corporations (February 22, 1991), p. 1.

Quaker Oats Spin Approved, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 8.

IRS Claims Against Federated Add Up, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 7.

Partnership Roll-Ups Trigger Tax, Other Problems, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 7.

Contingent Value Rings Raise Tax Issues, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 7.

Mortgage Swap Deals Scrutinized, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 6.

Greenmail Deduction Denied to Stokely-Van Camp, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 5.

New Developments in Dividends, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 5.

Liquidation-Reincorporation Revisited, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 3.

Interest Reporting Acquisitions, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 3.

Amortizing a TV Franchise Without Reducing Basis, Vol. 1, No. 10, Taxation of Mergers & Acquisitions (February 1991), p. 2.

National Starch Revisited: TAM Offers New Planning For Deductions of Takeover Expenses, Vol. 3, No. 5, Corporate Taxation (January/February 1991), p. 11.

S Corporations Shield Owner From $19 Million Massachusetts Assessment, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 4.

New York Resident’s Personal Income Tax Credit Available to Shareholder for S Corporation taxes Paid to Other States, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 4.

Can a Nonresident Alien Be an S Shareholder?, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 3.

Different Shareholders Revoke Election: New S Election Available Without Five-Year Wait, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 3.

Minority Shareholder Held Not to Be “Responsible Person” For Payroll Tax Purposes, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 2.

IRS Expands No-Rule List, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 2.

Disproportionate Distribution Rule Continues to Raise Problems, Vol. 7, No. 4, S Corporations Tax Bulletin, S Corporations (January 17, 1991), p. 1.

The Taxable Income Limit and Built-in Gain Tax, S Corporations (January 17, 1991), p. 4267.

New One Class of Stock Rules Impact S Class Corporation, Vol. 9, No. 1, Real Estate Tax Digest (January 1991), p. 3.

No-Ruling List Expanded, Vol. 1, No. 9, Taxation of Mergers & Acquisitions (January 1991), p. 4.

Third Circuit Says More on National Starch, Vol. 1, No. 9, Taxation of Mergers & Acquisitions (January 1991), p. 7.

Terminations and Revocations of Elections: Re-Elections, Vol. 3, No. 4, S Corporations Journal (Winter 1990/1991), p. 335.

 

MISCELLANEOUS

 

Grant of Historical Facade Easement Held a Disposition, Vol. 19, No. 1, Journal of Real Estate Taxation (Fall 1991), p. 64.

Powers of Attorney Are Taxable, Vol. 7, No. 10, S Corporations Tax Bulletin, S Corporations (July 18, 1991), p. 6.

Structuring Around Property Tax Assessments, Vol. 9, No. 3, Real Estate Tax Digest (March 1991), p. 53.

Charitable Contributions of Property, Vol. 18, No. 3, Journal of Real Estate Taxation (Spring 1991), p. 282.

Determining Highest and Best Use, by Robert W. Wood and Jill S. Dodd, Vol. 18, No. 2, Journal of Real Estate Taxation (Winter 1991), p. 172.

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