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59 Taxes 1 (1981)

handle is hein.journals/taxtm59 and id is 1 raw text is: aGNFFE .T/L TAX MAGAZINE This magazlne 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 CCII 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 Washingtoa Editor James R. lcNelis Business Manager James L. Jones Circulation Manager Donald B. Izban TAAE)h--The Tax Maga- zie (ISSN 0040-0181) is published monthly by Commerce Clearing House, Inc., 4025 W. Peterson Ave_ Chicago, Illinois 60646. Second-class post- age paid at Chicago, Illi- nois. Postmaster: Send address changes to TAXES -The Tax Magazine, 4025 W. Peterson Ave. Chi cago, Illinois 60646 Seb- scripltion rate: $45, 1 year; $4 single copy. January, 1981. Vol. 59, 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. jl 1980, Commerce Clearing House, Inc. All rights reserved. Printed in U. S. A. ~TS JANUARY 1981 * VOL. 59 No. 1 T a x N o te s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 No Smooth Sailing for Fiduciaries Waiving Attribution in Stock Redemp- t io n s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3 Allaire Urban Karzon examines three recent cases that have challenged exist- ing concepts concerning the ability of a fiduciary to waive attribution in a stock redemption under Section 302(b)(3). Valuation by Actuarial Tables-is It Mandatory? .................... 12 According to Edward J. Schnee and Ronald L. Taylor, the IRS has now classi- fied its position on the use of actuarial tables in the valuation of assets when the valuation is dependent on the life expectancy of an individual. Using Section 337 in a C Reorganization: Impact of General House- w a re s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 8 Charles E. Chromow analyzes the use of Section 337 in C reorganizations in the light of the decision in General Housewares v. U. S. In W ashing ton . . . . . . . . . . . . . . . . . . . . . . .. . . .. . . . . . .. . . .. .. .. . 2 4 Nonmarketability Discounts Should Exceed Fifty Percent .............. 25 George S. Arneson takes a look at several factors used in determining the discount for lack of marketability of letter stocks. Tax Pointer-Here Are Tax Areas the IRS Will Focus On in '81 ........ 32 Section 7203 and the Fifth Amendment Privilege: New Developments Discourage Taxpayers .... ................................. 33 Several recent cases, in which taxpayers claimed the privilege against self- incrimination in their refusal to fill out income tax forms, are considered by William Raabe, Jr. From the Thoughtful Tax Advisor ............................... 39 The IRS's drive to tighten controls against tax return preparers is examined by John W. Harris and William J. Salica. How to Deal with the Collection Division-Reaction and Reply ......... 42 A response by J. R. Starkey, Director of the Collection Division of the Internal Revenue Service, to a recent article by Randy Bruce Blaustein is presented, along with Mr. Blaustein's reply. Exercise Caution in Forming Section 337 Liquidating Trusts ........... 44 The effect of Revenue Procedure 79-1 on liquidating trusts is discussed by Jonathan A. Brod, who offers some suggestions to corporations whose liqui- dating situation does not fit the requirements of this revenue procedure. S tate T axes . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 5 2 The Sem i-private Foundation .................................. 53 An alternative to the private foundation-the common, or pooled, fund, as described in Section 170-is suggested by James M. Cowley and Lee 0. Case. Contribution of Property to Keogh Plans ......................... 57 Edward Binkowski focuses on the advantages of contributions of property, instead of cash, to retirement plans by the self-employed. Tax M eetings .. ....................................... ..... 64

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