Table Of ContentIndex to Volume 8
Author Index
BELL, WILLIAM W. & SHOEMAKER, DAVID B., International
Developments:
Foreign Direct Investment in U.S. Real Estate: The Screws Tighten 258
374 JOURNAL OF PARTNERSHIP TAXATION
BRENMAN, LAWRENCE H., Amended Temporary Passive Loss
Regulations Clarify Developer Rule, but Problems Remain
Tax-Oriented Investments: An Exit Strategy for Partners: Aban-
donment of Partnership Interests
A Lesson in Fractions: How to Attract Capital From Tax-Exempt
Investors
CARMAN, WILLIAM T. & DANCE, GLENN E., Accounting Issues:
Even Charitable Contributions by Partnerships Can Be Complex! 80
Failure to Pay the Piper Can Accelerate a Requirement to Pay
Uncle Sam
CARMAN, WILLIAM T. & ZOOT, JORDAN, Accounting Issues:
Having Tax-Exempt Partners Can Be a Taxing Proposition
COMITER, RICHARD B. & LOONEY, STEPHEN R., S Corpora-
tions:
Uncertain Application of the Statute of Limitations to § Corpora-
tions and Their Shareholders
CUFF, TERENCE F., Proper Drafting Can Resolve Problems Created
by the Minimum Gain Chargeback
CULLINS, JOHN W., MILLER, NANCY L. & MONTGOMERY,
STEVE, Washington Tax Watch:
Treasury Revises Liability Allocation Rules
GRACE, MICHAEL J., Self-Charged Interest Regulations Ease Con-
sequences of Partner-Partnership Loans
HART, KENNETH M., Partnership Agreements That Cope With
Restoration of Deficit Capital Accounts
LOSEY, F. RICHARD, Recent Cases and Rulings 87, 182, 346
MARCHBANKS, MICHAEL, How Should Dual Capacity Partners
Be Treated for Income Tax Purposes? ............c00eeeeeee 146
MARK, RICHARD S. & ROBISON, JACK, Numerous Options Exist
for Specially Allocating Depletion, but Which Is Best?......... 329
MONTGOMERY, STEVE & BOBROW, RICHARD S., Washington
Tax Watch:
K-1 Simplification
Partnership Audit and Administration Proposals
PURINTUN, ANN-ELIZABETH, Partnership Procedure:
FPAA Valid Despite Untimely Commencement Notice
REEVES, RON L. & SHAPLEIGH, COLBERT C., Effect of Dis-
charge of Indebtedness Income on Partnerships and Partners .. .
RUBIN, BLAKE D. & CAVANAGH, RITA A., Guidelines for Using
a Partnership Freeze to Reduce Corporate Taxes: Part II
SANSWEET, JEFFREY B., Selecting the Most Favorable Retirement
Plan for a Service Partnership
SCHOENBRUN, GARY L., Consequences of Preferred Return Provi-
sions in a Partnership Agreement
INDEX TO VOLUME 8
SMILEY, STAFFORD, Dispositions of U.S. Partnership Interests by
Nonresident Aliens
SNOW, GERALD T., Family Partnership Rules Add Complexity to
Partnership Allocations
STOLBACH, GARY, WALLACE, TODD & EVAUL, DAVID, New
Estate Freeze Rules: Gift Leveraging Can Achieve Estate Planning
Objectives
New Estate Freeze Rules: Practical Issues for Gift Leveraging ..
TOUSEY, CLAY B., JR. & WALLIS, DONALD W., Estate Planning:
Availability of Section 754 Election Is an Important Consideration
in Estate Planning for Owners of Closely Held Businesses 93
The Effect of Death of a Partner on the Continuing Existence of
the Partnership for Tax Purposes 283
Title Index
Accounting Issues, William T. Carman & Glenn E. Dance:
Even Charitable Contributions by Partnerships Can Be Complex!
Failure to Pay the Piper Can Accelerate a Requirement to Pay
Accounting Issues, William T. Carman & Jordan S. Zoot:
Having Tax-Exempt Partners Can Be a Taxing Proposition
Amended Temporary Passive Loss Regulations Clarify Developer
Rule, but Problems Remain, Lawrence H. Brenman
Consequences of Preferred Return Provisions in a Partnership Agree-
ment, Gary L. Schoenbrun
Dispositions of U.S. Partnership Interests by Nonresident Aliens,
Stafford Smiley
Effect of Discharge of Indebtedness Income on Partnerships and
Partners, Ron L. Reeves & Colbert C. Shapleigh
Estate Planning, Clay B. Tousey, Jr. & Donald W. Wallis:
Availability of Section 754 Election Is an Important Consideration
in Estate Planning for Owners of Closely Held Businesses
The Effect of Death of a Partner on the Continuing Existence of
the Partnership for Tax Purposes
Family Partnership Rules Add Complexity to Partnership Allocations,
Gerald T. Snow
Guidelines for Using a Partnership Freeze to Reduce Corporate Taxes:
Part II, Blake D. Rubin & Rita A. Cavanagh
How Should Dual Capacity Partners Be Treated for Income Tax
Purposes? Michael L. Marchbanks
International Developments, William W. Bell & David B. Shoemaker:
Foreign Direct Investment in U.S. Real Estate: The Screws
Tighten
376 JOURNAL OF PARTNERSHIP TAXATION
New Estate Freeze Rules: Gift Leveraging Can Achieve Estate Planning
Objectives, Gary Stolbach, Todd Wallace & David Evaul
New Estate Freeze Rules: Practical Issues for Gift Leveraging, Gary
Stolbach, Todd Wallace & David Evaul
Numerous Options Exist for Specially Allocating Depletion, but Which
Is Best?, Richard S. Mark & Jack Robison
Partnership Agreements That Cope With Restoration of Deficit Capital
Accounts, Kenneth M. Hart
Partnership Procedure, Ann-Elizabeth Purintun:
FPAA Valid Despite Untimely Commencement Notice
Proper Drafting Can Resolve Problems Created by the Minimum Gain
Chargeback, Terence F. Cuff
Recent Cases and Rulings, F. Richard Losey
S Corporations, Richard B. Comiter & Stephen R. Looney:
Uncertain Application of the Statute of Limitations to S Corpora-
tions and Their Shareholders
Selecting the Most Favorable Retirement Plan for a Service Partnership,
Jeffrey B. Sansweet
Self-Charged Interest Regulations Ease Consequences of Partner-Part-
nership Loans, Michael J. Grace
Tax-Oriented Investments, Lawrence H. Brenman:
An Exit Strategy for Partners: Abandonment of Partnership
Interests
A Lesson in Fractions: How to Attract Capital From Tax-Exempt
Investors
Washington Tax Watch, John W. Cullins, Nancy L. Miller & Steve
Montgomery:
Treasury Revises Liability Allocation Rules
Washington Tax Watch, Steve Montgomery & Richard S. Bobrow:
K-1 Simplification
Partnership Audit and Administration Proposals
wee
