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68 Taxes 1 (1990)

handle is hein.journals/taxtm68 and id is 1 raw text is: -7/ TAX MAGAZINE a JANUARY 1990 o VOL. 68 NO. 1 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 CCH Tax Law Editors 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 Maureen K. Schwartz Washington Editor Paul B. Alligood Business Manager James A. Merchant Circulation Manager Donald B. Izban Production Barbara A. Wrobel TAXES-The Tax Maga- zine (ISSN 0040-0181) Is published monthly by Commerce Clearing House, Inc., 4025 W. Peterson Ave., Chicago, IL 60646. Second-class postage paid at Chicago, Illinois. POST- MASTER: SEND AD- DRESS CHANGES TO TAXES-The Tax Maga- zine, 4025 W. PETERSON AVE., CHICAGO, ILLI- NOIS 60646. Subscription rate: $90, 1 year: $10 single copy. January 1990, Vol. 68, No. 1. Change of ad- dress should be received at least 30 days before the date of the issue with which it Is to take effect. C 1989, Commerce Clear- ing House. Inc. All rights reserved. Printed in U.S.A. Thus Spake the Commissioner: Advance Notice 89-99 and the Scope of the Section 2036(c) Estate Freeze Ban .......................... Long-awaited guidelines regarding estate freezes have finally been issued by the IRS. Hamlin C. King explores the impact that Notice 89-99 will have on estate planning. IRC Section 460: Long-Term Construction Contract Issues ........... Sheldon D. Pollack analyzes the new long-term contract accounting rules under Section 460, their application to construction contracts typically used by residential real estate developers, and the impact of Notice 89-15 on taxpayers who, prior to 1989, had treated their long-term construction con- tracts as not subject to Section 460. Determining Valid Legal Authority in Advising Clients, Rendering Opin- ions, Preparing Tax Returns and Avoiding Penalties: The Impact of IM P A C T . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . Updating an earlier TAXES article, Sheldon I. Banoff considers what consti- tutes good legal authority in avoiding penalties on tax returns in light of the Improved Penalty Administration and Compliance Tax Act of 1989. Unwrapping the ESOP Package ................................ Arthur H. Kroll and Andrew L. Oringer discuss, among other issues, the use of proceeds from the sale of suspense account stock to extinguish ESOP debt. Avoiding Controlled Group Status: Growing Motivations and Challenges. Joseph R. Oliver focuses on ways in which multiple corporations may avoid single-entity status. Uniform Capitalization and the Oil and Gas Industry: The Challenge of C o m p lia nce . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . The application of the UNICAP rules to oil and gas producers, including special problems that result under the rules, is explored by Patrick Hennessee and Stephanie Bone. Assignment of Income: Gifts of Stock and Dividend Income ........... Janet A. Meade examines the effect of a recent court of appeals decision allowing a taxpayer to avoid recognition of income on gifts of stock taking place between the dividend declaration date and the date of record. Tax Pointer-New Standard Mileage Rate Rule Favors Taxpayers ...... DEPARTMENTS: T ax N o tes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . In W ashington . .. .. .. .. .. .. .. .. .. .. .. .. .. .......... ....... International Journal ........................................ S tate T axes . .. . . . . . . . . . . . . . . .. . . . . . . . . . . . . . . . . . . . . . . . . . . . Tax M eetings ....................... .... ..................

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