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60 Taxes 1 (1982)

handle is hein.journals/taxtm60 and id is 1 raw text is: 2&Iic TAX MAGAZINE This magazine is pub- lished to promote sound thought In economic, legal and accounting principles relating to all federal and state taxation. To this end it contains signed articles on tax subjects of current interest and re- ports by the OC(H Editorial Staff on recent federal and state tax matters. The editorial policy Is to allow frank discussion of tax issues. On this basis contributions are Invited. Responsibility Is not as- sumed for the contents of the articles or for the opinions expressed therein. Editor Gene 0. SJostrand Washington Editor James R. McNells Busins Manager James A. Merchant .0iruZation Manager Donald B. Izban 'AXES--T', Tax Maga- sine (ISSN 0040-01A1) Is published monthly by Commerce Clearing House, Inc., 4025 W. Peterson Ave., Chicago, IL 60646. Second-clas postage paid at Chicago, Illinois. POSTV NASTX : SEND AD- DRESS CHANGES TO TAXES-The Tw Maga- sit, 4025 W. PETERSON AVE.. CHICAGO, ILW- NOIS 60646. Subbcrition toe: 00, 1 year: $5 single copy. January. 1W. Vol. 60. No. 1. Change of address should be received at least 30 days before the date of the Issue with which it Is to take effect 0 1961. Commerce Clear- ing House, Inc. All rights reserved. Printed in U.S.A. JANUARY 1982 * VOL. 60 No. 1 T a x N o te s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 Royalty Owners and the Windfall Profit Tax ...................... 3 Craig E. Reese analyzes the royalty owner's credit and the small-volume royalty owner's exemption from the windfall profit tax. State Taxes ................................................. 15 Revisiting the Uneasy Case for Progressive Taxation ............... 16 Recent economic and social trends, argues Walter J. Blum, diminish an al- ready uneasy justification for a highly progressive rate of taxation in the United States. Estate Planning After the Economic Recovery Tax Act of 1981 ....... 22 The effect of the Economic Recovery Tax Act of 1981 on the value and importance of estate planning is examined by Joseph E. Doussard. Business Start-Up Expenses and Section 195: Some Unresolved Problems 27 Lewis D. Solomon and Alan Weintraub focus on the enactment of Section 195 on the deductibility of various kinds of business start-up expenses. Church Plans ................................................ 33 The effect of the Multiemployer Pension Plan Amendments Act of 1980 on classification of church plans is discussed by Thomas G. Tracy. The Professional Corporation and the Gift-Leaseback: Shifting Income by Means of an Equipment Trust .............................. 49 Andrew C. Mallor describes the procedures he believes will provide a greater likelihood that a gift-leaseback arrangement by means of an equipment trust will be able to withstand attack by the IRS. In W ashington ............................................. 54 Extension of the At-Risk Rules to the Investment Tax Credit: A Further Legislative Attack on Tax Shelter Investments .................. 55 The amendment of Section 46 to provide that the basis of property eligible for the investment tax credit may not exceed the taxpayer's amount at risk is discussea by Paul J. Streer and Kenneth H. Heller. Emerging Criteria for Tax-Exempt Classification for Religious Orga- n izatio ns . . . . . . . . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . 6 1 The criteria for classification of religious organizations as tax exempt are analyzed by Kenneth E. Peacock. Issuance and Enforcement of IRS Summonses Against Third-Party Recoidkeepers .......................................... 66 Bonnie Smith Moses reviews the discovery powers of the IRS against third- party recordkeepers as decided by the courts. Tax Meetings ................................................ 80

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