TAXATION

Acquisition of Loss Corporations and Retention of Loss Carry-Overs…..12:71

The Allocation of Taxable Income Between Husband and Wife…..26:371

The Applicability of I.R.C. Section 108 to Cancellation of Indebtedness by a Transfer of Property…..33:133

Application of Sales Tax to Occasional and Isolated Sales…..12:81

Application of the Transfer for Value Rule Under Internal Revenue Code Section 101(a)…..28:953

Arkansas Best Corp. v. Commissioner, 108 S. Ct. 971 (1988)—A Taxpayer’s Motivation in Purchasing an Asset Is Irrelevant to the Question Whether It Falls Within the Broad Definition of “Capital Asset” in Internal Revenue Code Section 1221…..38:943

Bankers Life Co. v. United States (8th Cir. 1978)—Life Insurance Agents’ Debit Balances and Mortgage Escrow Funds Are Considered Assets for Tax Purposes While the Lending Portion of Due and Deferred Premiums Are Not Assets Within the Meaning of the Life Insurance Company Income Tax Act of 1959…..27:784

A Call for IRS Guidance in Drafting Tax Liability Divorce Clauses in Anticipation of Innocent Spouse Litigation…..52:363

The Captive Insurance Agent—A Last Hurrah for an Independent Contractor?…..25:845

Classifying Shareholder Advances to a Closely Held Corporation as Debt or Stock: Guidelines for the Befuddled Practitioner…..33:641

Commissioner v. Tufts (U.S. Sup. Ct. 1983)—A Taxpayer Must Include the Total Nonrecourse Obligation on Encumbered Property in Amount Realized upon Disposition of Property and the Fair Market Value of the Property Is Irrelevant to that Calculation…..33:433

Conditional Gifts: The Demise of Donative Intent in Income Tax Analysis…..32:503

The Continued Folly of the Innocent Spouse Defense: Is It Viable?…..45:551

The Criteria the Tax Court Uses in Determining if the Taxpayer Is Liable for the Fraud Penalty…..37:445

Decedent’s Rental of Real Estate: Application of Internal Revenue Code Sections 2032A and 6166…..33:371

Demise of the Beamed Transfer Theory—A Result of Legislative Ambiguity…..40:561

Divorce and Taxation—A New Emphasis in Iowa…..30:273

Double Death Taxation: Avoidance and Remedies…..32:731

“Employers” Subject to the Iowa Employment Security Law…..4:28

The ERISA Amendment Provision As a Disclosure Function: Including Workable Termination Procedures in the Functional Purpose of Section 402(b)(3)…..46:755

ERISA, FASB, and Benefit Plan Amendments: A Section 402(b)(3) Violation As a Loss Contingency for a Plan Amendment…..46:97

Estate and Death Tax Planning for Non-Residents Owning Iowa Real Estate…..35:529

Estate of Lincoln v. Briggs (Iowa 1972)—The Unpaid Purchase Price of Real Estate Situated in Another State, Evidenced by Articles of Agreement, Executed by the Decedent Vendor, Is Properly Subject to a Succession Inheritance Tax in the State of the Owner’s Domicile…..22:422

Evaluating a Subchapter S Conversion…..37:395

Exclusion of Personal Injury Damages from Gross Income Under I.R.C. Section 104(a)(2)…..37:643

Farm Taxation: Lesson from History…..37:183

Federal Estate Taxation of Life Insurance: You Can’t Take It With You and It’s Often Hard to Leave It Behind…..21:682

Federal Tax Liens, Their Priority and Enforcement…..10:3

Federal Transfer Tax Treatment of Actuarial Appreciation…..42:123

Federal Tax Treatment of Medical Malpractice Insurance Alternatives for Nonprofits…..52:495

Financing the Future: Interpreting the “Economic Development Area” Provision of the Iowa TIF Statute…..50:159

Income Shifting Devices—Time to Shift from Clifford Trusts to Subchapter-S Corporations?…..36:585

Income Tax and the Iowa Lawyer…..17:11

The Iowa Personal Earnings Exemption—Recent Legislation…..7/1:79

Iowa Stamps on Drugs: A Constitutional Analysis of Iowa Code Chapter 453B…..44:81

Iowa Tax Amnesty: Was It a Success?…..36:551

Iowa Tax Law and Procedure—1971…..21:282

Iowa Tax Law and Procedure—1972…..22:550

Iowa Tax Law and Procedure—1973…..23:386

Iowa Tax Law and Procedure—1974…..24:370

Iowa Tax Law and Procedure—1975-1976…..26:331

Iowa Tax Law and Procedure—1977-1978 (Survey of Iowa Law)…..28:599

Iowa Tax Law and Procedure—1979-1980 (Survey of Iowa Law)…..30:503

Iowa Tax Laws and Procedure)…..19:379

The Iowa Title Standards I…..2:76

The Iowa Title Standards II…..3:36

The Iowa Title Standards III…..3:87

The Iowa Uniform Gifts to Minors Act…..9:32

Iowa Use Tax, The…..11:108

IRS Summonses to Known Individuals: Eighth Circuit Practice…..34:135

Jackson v. Statler Foundation (2d Cir. 1974)—Granting of State Tax Exemptions to Private Charitable Foundation Held Sufficient to Establish State Action Under the Equal Protection Clause of the Fourteenth Amendment…..24:425

Kraft General Foods, Inc. v. Iowa Department of Revenue & Finance, 112 S. Ct. 2365 (1992)…..43:489

Late Filing of Federal Estate Tax Returns: Reliance on Attorney as Reasonable Cause…..32:157

Life Insurance in Estate Planning—Taxation and Uses Today…..35:773

Lifetime Gifts in Estate Planning Under the 1976 Tax Reform Act…..26:313

Lockwood v. United States, 181 F. Supp. 748 (S.D.N.Y. 1959)—Is Property Given Away by Eighty-Seven Year Old Donor, Who Died Within Nine Months After Making the Gift, to Be Included in Donor’s Estate as a Gift in Contemplation of Death, When One of the Donor’s Principal Motives Was to Reduce Income Taxes, to Which he Was Unalterably Opposed?…..10:144

Loewen v. Commissioner (Tax Court 1981)—Investment Tax Credit Recapture—Taxpayer’s Transfer of all Farm Assets Except Farmland to Wholly Owned Corporation Did Not Cause Recapture when State Law Made Questionable Corporate Ownership of Farm Land…..31:673

Metropolitan Life Insurance Co. v. Ward, 470 U.S. 869 (1985)—An Alabama Domestic Preference Tax Statute that Taxes Out-of-State Insurance Companies at a Rate Higher than Domestic Insurance Companies Violates the Equal Protection Clause of the United States Constitution…..35:921

Michaelson v. United States, 203 F. Supp. 830 (E.D. Wash. 1961)—When May Educational Expenses Be Deductible as Business Expenses…..12:84

Missouri v. Jenkins, 110 S. Ct. 1651 (1990)—Principles of Comity Prohibit Federal Courts from Directly Imposing State Tax Levy Increases. Federal Courts Have the Authority, However, to Order School Districts to Levy Taxes in Excess of Limits Set by State Law to Fund Court-Ordered Desegregation Plans…..41:223

Modern Tragedies and Myths: The Passive Activity Loss Rule…..37:431

The New Iowa Income Tax Regulations…..5:15

Oliver v. United States, 193 F. Supp. 930 (E.D. Ark. 1961)—Was Payment in 1958 by Farmer’s Cooperative to Member for Rice Delivered to Cooperative in 1957 Constructively Received by the Member in 1957?…..11:68

An Overview of State Taxation of Individual and Corporate Income in Iowa…..26:57

Pennsylvania Bank & Trust Co. v. United States (3rd Cir. 1979)—“Exercisable” in I.R.C. Section 2041 Refers to the Scope of the Power Set Forth in the Granting Instrument, Not to the Donee’s Actual Capacity to Exercise It, and Therefore, a Decedent’s Incompetency to Exercise His General Power of Appointment Is Immaterial for Estate Tax Purposes…..29:479

“The Power to Tax Involves the Power to Destroy”…..50:315

Prepaid Feed Expense: Another Look at the Deposit, Business Purpose, and Distortion of Income Tests…..31:653

Recent Developments in Iowa Tax Law and Procedure—1970 (Survey of Iowa Law)…..20:626

Repeal of the Death Tax? Shoving Aside the Rhetoric to Determine the Consequences of the Economic Growth and Tax Relief Reconciliation Act of 2001…..51:633

The Role of the Subsidiary in Corporate Reorganization…..18:175

Section 2032A: Did We Save the Family Farm?…..29:15

Section 6166: Preserving the Family Business or Family Farm Through Estate Tax Deferral…..25:521

Section 6851 Termination of a Taxable Year: The Search for a Taxpayer Remedy…..24:683

Severance Taxes and Soil Depletion: Is Grain a Natural Resource Amenable to Severance Taxation?…..31:621

Special Assessments for Public Improvements in Iowa—Part I—From Birth of the Idea to Soliciting Bids…..12:3

Special Assessments for Public Improvements in Iowa—Part II—Further Pre-Assessment Procedure…..13:25

Special Assessments for Public Improvements in Iowa—Part III—Making the Assessment…..14:3

Special Assessments for Public Improvements in Iowa—Part IV—Judicial Review…..15:3

Special Assessments for Public Improvements in Iowa—Part V—Reassessment, Collection, Liability and Conclusion…..16:3

State of Minnesota v. Fairview Hospital Association, 114 N.W.2d 598 (Minn. 1962)—Exemption of Charitable, Religious and Educational Institutions from Property Taxes…..12:87

State Taxation of Mail Order Insurers…..24:825

Tax Aspects of Charitable Giving…..5:85

Tax Status of Professional “Kickbacks”…..1:72

Tax, Turpitude, and a Technical Test for Disbarment…..17:94

Taxing the One-Man Corporation…..6:98

Taxation of Electronic Commerce: Avoiding an Inroad upon Federalism…..49:465

Title Problems in Connection with Federal Tax Liens…..10:28

The Unrecorded Sales Tax Lien…..5:51

Useful Life and Salvage Value: Changing Concepts…..7/1:32

Would Caesar Tax God? The Constitutionality of Governmental Taxation of Churches…..35:383