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61 Taxes 1 (1983)

handle is hein.journals/taxtm61 and id is 1 raw text is: .JA 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 (OH 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 Busness Manager James A. Merchant Circudation Manager Donald B. Izban TAXE--Tie Tax Maa- me (ISSN 0040-0181) Is published monthly by Commerce Clearing House, Inc.. 4025 W. Peterson Ave., Chicago, IL 60646. Second-class postage paid at Chicago, llinois. POSTV NASTUR: SEND AD- DRESS CHANGES TO TAXES-T Tag Maga- sift, 4025 W. PETERSON AVE., CHICAGO, ILW- NOIS 60646. Subscripton te: 50, 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. S1961. Commerce Clear- ing House, Inc. All rights reserved. Printed In U.S.A. JANUARY 1983 o VOL. 61 No. 1 T a x N o te s . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... . . . 2 Modern Marital/Charitable Estate Planning ........................ 3 Jerry J. McCoy and Lynda S. Moerschbaecher discuss the Code provisions granting deductions for the creation of trusts which provide a life interest for a surviving spouse, followed by a charitable disposition, and analyze the tax planning opportunities arising from these changes. Goal Tending Called on Net Gifts ................................ 13 The effect of the Supreme Court case of Diedrich v. Commissioner on the status of net giving and the uses that remain for net gifts are considered by LeRoy L. Metz and Wesley Yang. In W ashington . ... ... ... .... ...... .... ....... ...... .. ... .. 19 Industrial Development Bonds After TEFRA ....................... 20 Gary J. Winston describes the principal changes made to the rules governing the issuance of industrial development bonds by the Tax Equity and Fiscal Responsibility Act of 1982 and explains how these changes will affect the availability of industrial development bond financing. From the Thoughtful Tax Advisor ................................ 28 the prospect of preserving the benefits of personal service corporations after the changes brought about by the Tax Equity and Fiscal Responsibility Act of 1982 is focused on by Joseph H. Ingram. Life Insurance Company Gross Investment Income: The Dilemma Under the Section 804 (b) Definition .......31 J. Walker Johnson examines two interpretations of what constitutes life insur- ance company' gross investment income under Section 804(b) and suggests ways in which the differences between these two interpretations may be resolved. The Investment Company Discount: Estate of Folks and Beyond ....... 47 The implications of the Tax Court's decision in Estate of Folks for investment company discounts for majority interests in an operating company are ana- lyzed by David M. Obstler. The Sub-S-Burg Address ... ................................... so Matthew C. Kessler provides a modern restatement of a classic speech. S tate T axes . . . . . . . . . . . . . . . . .. . .. . . . . .. .. . . . . .. . . . .. . . . . . . 5 1 Now Penalty Provisions and Their Effect on Aggressive Tax Planning .. 52 Randall W. Roth considers how the new penalty provisions added by the Tax Equity and Fiscal Responsibility Act of 1982 will affect aggressive tax planning for both the taxpayer and the practitioner. Timber Tax Incentives and the Small Investor ...................... 59 The timber tax incentives in the Code, according to Paul J. Streer and Keith A. Utz, make timber investment useful in accumulating funds for retirement. Tax Consequences of Annulments .............. ............... 65 James T. Tilt and Martin M. Spencer examine the potential tax advantages and disadvantages resulting from the annulment of a marriage. Tax Pointer-Hardship Delays Provided for Pension Withholding ...... 71 T ax M ee ting s . . . .. . . .. . . . . . . .. . .. . . . .. . .. .. . . .. .. . .. . . . .. . 72

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