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63 Taxes 1 (1985)

handle is hein.journals/taxtm63 and id is 1 raw text is: .7Iic 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
Businss Manager
James A. Merchant
Circudation Manager
Donald B. Izban
T'AXEH--The Tam Maga-
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, Illinois. POSTV
NAST R:     SEND     AD-
DRESS    CHANGES     TO
TAXES-Tw Tow Maga-
sife, 4025 W. PETERSON
AVE.. CHICAGO, ILW-
NOIS 60646. Subwription
ote: 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 effeC
S1961, Commerce Clear-
Ing House, Inc. All rights
reserved. Printed in U.S.A.

JANUARY 1985 * VOL. 63 No. 1
Tax  Notes    ................................................      2
Planning for the Taxation of Social Security Benefits .................. 3
Martha A. McSteen discusses the new law taxing Social Security benefits and
the arrangements that have been made by the Social Security Administration
to implement the law.
The  Strange  and  Untimely  Death  of Lester  ......................  9
Recent changes in the deductibility of payments to support minor children
pursuant to a divorce decree are examined by Joseph N. DuCanto.
St. John: New Standards to Be Applied to Partners' Profits Interest ....  14
David R. Bower and Colbert C. Shapleigh explore the significance of a recent
district court decision concerning the taxation of a partnership profits interests
received by a partner in return for services rendered.
State Taxes ...................................................... 19
Capital Gains and the Relinquishment of Contract Rights ............... 20
The tax treatment of capital received cs a result of a relinquishment of con-
tract rights is analyzed.by Philip G. Cohen.
From  the  Thoughtful Tax  Advisor  ..............................  28
Alan Gunn takes a look at the literal way in which some commentators have
interpreted Code Section 722, concerning whether there is an increase in
basis upon contribution of property to a partnership where gain is
recognized.
In  W ashing ton  . . . .. .. .. .. .. .. .. . . .. . . . . .. .. .. . . . . .. .. . . .. .  3 2
The Weight of the Law Now Supports Increased Tax Planning Possibili-
ties  for  Casualty  Losses  ...................................  33
Thomas L. Dickens and Michael J. R. Hoffman present a model to be used by
taxpayers who sustain uncompensated casualty or theft losses on business or
income-producing property in light of recent court decisions.
Group-Term Life Insurance Revisited: Has the Storm Become a Hurricane? 43
Recent efforts by the IRS and Congress to end perceived abuses and dis-
crimination in 'group-term life insurance plans are discussed by Gary
D. Aronowitz.
Tax Pointer-Ineffective Election Forces Carryback of NOL .......... 53
State Taxation of Computer Programs: Tangible or Intangible? ........ 54
David C. Tunick and Dan S. Schechter review decisions by several state courts
to treat computer softwcre as tangible or intangible property.
The Evolving Definition of Trade or Business: Ditunno and Beyond . .  73
Rodger A. Boiling and Wmi. Brent Carper briefly review the history of the
phrase trade or business and its evolution through the Ditunno decision,
discuss a possible relationship between the rationale behind Ditunno and the
hobby loss rules of Section 183, and finally comment on the significance of
the Tax Court's new position.
Tax  M eetings  ................... .... .... ..................   8 0

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