Author Index

Twelve Months Ended December 2005

AICPA TAX DIVISIONS
PARTNERSHIP TAXATION
TECHNICAL RESOURCE PANEL

Partnership Elections Grid. 05:200.

ANDERSON, SUSAN E.

Tax Planning for Land Preparation Costs. 05:276.

BOUCHER, KAREN J.

State & Local Taxes: Current Corporate Income Tax Developments. (Part I) 05:162. (Part II) 05:221.

BRISKIN, ROBERT A.

Like-Kind ExchangesCommon Problems and Solutions. 05:204.

BROWN, EDWARD D.

Third-Party Trusts Integrate Estate and Asset-Protection Planning. 05:490.

BURTON, HUGHLENE A.

Partners & Partnerships: Current Developments. 05:106.
S Corporations: Current Developments. (Part I) 05:626. (Part II) 05:694.

CANTRELL, CAROL A.

New Sec. 643 Trustee Capital Gain and Loss Carryout Regs. 05:733.

CARSLAW, CHARLES

How the AMT Affects Long-Term Capital Gain Rates. 05:544.

CHUI, YIDAN

Corporations & Shareholders: Significant Recent Developments. 05:32.

CLEGG, JASON

State & Local Taxes: Current Corporate Income Tax Developments. (Part I) 05:162. (Part II) 05:221.

COOK, ELLEN D.

Tax Benefits for Military Personnel. 05:87.
WFTRAs Individual Income Tax Provisions. 05:98.

CUMMINGS, JASPER L.

Chief Tax Officer Reporting Structures. 05:620.

DIGIANTOMMASO, ROBERT M.

LLC and LLP Issues for Small, Privately Owned Businesses. 05:24.

DILLEY, STEVE

Sale of a Residence and Like-Kind Exchanges. (Part I) 05:678. (Part II) 05:746.

ELLENTUCK, ALBERT B.

For Case Study, see the cover of each issue.

EVANS, LORRAINE D.

Tax Benefits for Military Personnel. 05:87.

EVERETT, JOHN O.

The Ins and Outs of Recapture. (Part I) 05:418. (Part II) 05:480.

FLEISCHMAN, GARY

Planning Strategies to Avoid Intermediate Sanctions. 05:424.

GRACE, DEBRA M.

The Ins and Outs of Recapture. (Part I) 05:418. (Part II) 05:480.

GUERTIN, SCOTT

FASB Exposure Draft on Uncertain Tax Positions. 05:612.

HABERMAN, MICHAEL

Employee Benefits & Pensions: Current Developments. (Part I) 05:684. (Part II) 05:752.

JACOBS, VERNON K.

Reporting and Disclosing Foreign Financial Accounts. 05:346.

KARLINSKY, STEWART S.

The AJCAs Domestic Business Provisions. 05:148.
S Corporations: Current Developments. (Part I) 05:626. (Part II). 05:694.

KELLEY, CLAUDIA L.

Tax Planning for Land Preparation Costs. 05:276.

KILLION, DAVID

Schedule M-3: Closing the Corporate Book-Tax Gap. 05:408.

LAFFIE, LESLI S.

For News Notes, see the cover of each issue.

LAU, PAUL C.

Forms of Overseas Operations. (Part I) 05:156. (Part II) 05:214.
New Rules on FTC Allocations. 05:354.

MASON, RICHARD

How the AMT Affects Long-Term Capital Gain Rates. 05:544.

MCGOWAN, JOHN R.

Schedule M-3: Closing the Corporate Book-Tax Gap. 05:408.

MILLS, JOHN

How the AMT Affects Long-Term Capital Gain Rates. 05:544.

MUNTEAN, MARK

Congresss Tax Double Header. 05:674.

NEMETH, JOHN

Corporations & Shareholders: Significant Recent Developments. 05:32.

NISSENBAUM, MARTIN

Significant Individual Provisions of the AJCA. 05:92.

ODRISCOLL, DAVID

For Tax Trends, see the cover of each issue.

OESTREICH, NATHAN

WFTRAs Individual Income Tax Provisions. 05:98.

ORBACH, KENNETH N.

The AJCAs Domestic Business Provisions. 05:148.
Sale of a Residence and Like-Kind Exchanges. (Part I) 05:678. (Part II) 05:746.

PONDA, SHONA

State & Local Taxes: Current Corporate Income Tax Developments. (Part I) 05:162. (Part II) 05:221.

PORTER, DAVID B.

The IRSs New EmphasisTax Enforcement. 05:541.

RAABE, WILLIAM A.

Tax and Investment Planning with Royalty Trusts. 05:484.

RANSOME, JUSTIN P.

New Regs. on Elections for Indirect Skips. 05:738.

RICHTERMEYER, SANDRA B.

Planning Strategies to Avoid Intermediate Sanctions. 05:424.

SANDERS, DEBRA L.

Tax and Investment Planning with Royalty Trusts. 05:484.

SATCHIT, VINU

Bongard: Tax Court Incorrectly Expands Sec. 2036(a)s Application. 05:476.

SAVOTH, PAUL G.

Income and Estate Tax Planning for Special Needs Trusts. 05:40.

SAWYERS, ROBY B.

Significant Recent Developments in Estate Planning. 05:550.

SCHADEWALD, MICHAEL S.

Deducting Related-Party Interest and Intangible Expenses. 05:286.

SCHNEIDER, MARK A.

Corporations & Shareholders: Significant Recent Developments. 05:32.

SHOWERS, SEAN

The Low-Income Housing CreditProgram Expansion and Investment Opportunities. 05:556.

SHUM, MICHAEL G.

Forms of Overseas Operations. (Part I) 05:156. (Part II) 05:214.
New Rules on FTC Allocations.
05:354.

SPOOR, F. GORDON

Final Regs. Define Income under Sec. 643. 05:280.

SULLIVAN, NEIL A.J.

U.S. Reporting Requirements for Canadian RRSPs/RRIFs. 05:146.

TERPENING, ROB

FASB Exposure Draft on Uncertain Tax Positions. 05:612.

TOOLSON, RICHARD B.

Tax and Investment Planning with Royalty Trusts. 05:484.

WALKER, DEBORAH

Employee Benefits & Pensions: Current Developments. (Part I) 05:684. (Part II) 05:752.

WHITLOCK, BRIAN T.

Significant Recent Developments in Estate Planning. 05:550.

WOOD, ROBERT W.

Deducting Legal Fees for Governmental Corporate Investigations. 05:341.
Structured Settlements and Nonqualified Assignments. 05:26.
Should Taxes Be Included in Damage Calculations? 05:614.

Campus to Clients

(For Tax Education entries, see p. 780)

NELLEN, ANNETTE

August 05:500.
November 05:704.

ANDERSON, SUSAN

Pro-Bono Tax Services: The Role of Tax Academics and Students. 05:500.

BAUMAN, CHRISTINE

Pro-Bono Tax Services: The Role of Tax Academics and Students. 05:500.

FISCHER, CAROL M.

Fitting Tax Policy into Tax Curricula. 05:704.

NICHOLS, NANCY

Pro-Bono Tax Services: The Role of Tax Academics and Students. 05:500.

OUTSLAY, ED

Pro-Bono Tax Services: The Role of Tax Academics and Students. 05:500.

RUPERT, TIMOTHY J.

Fitting Tax Policy into Tax Curricula. 05:704.

D.C. Currents

PURCELL, THOMAS J., III

TEC Initiatives. February 05:113.
TEC Initiatives. May 05:297.
TEC Initiatives. August 05:498.
TEC Initiatives. November 05:702.

On the Bookshelf

FINK, PHILIP R.

March 05:174.
June 05:366.
September 05:570.
December 05:772.

Personal Financial Planning

MINKER, MARC J.

July 05:433.
October 05:636.

CANTRELL, CAROL ANN

Partnership Interest for Services Regs. Offer Estate Planners a Bona Fide Solution. 05:636.

KAPLAN, JAY H.

A Primer on LTC Insurance. 05:45.

KAPLAN, PAMELA W.

A Primer on LTC Insurance. 05:45.

LEWIS, GEORGE A.

A Primer on LTC Insurance. 05:45.

PINCUS, ANDREW S.

Estate Planning with Life Insurance. 05:433.

WRIGHT, DEBRA

Marketing ElderCare/PrimePlus Services. 05:229.

State & Local Taxes

PETERSON, DANIEL F.

June 05:360.

SALMON, SCOTT

December 05:765.

FISHMAN, MARK D.

Streamlined Sales Tax Up and Runningand Affecting Many Businesses. 05:765.

HOGROIAN, FERDINAND

Streamlined Sales Tax Up and Runningand Affecting Many Businesses. 05:765.

NAKAMURA, KAREN

State Tax Implications of Employing Telecommuters. 05:360.

ROOD, DEBORAH

State Tax Implications of Employing Telecommuters. 05:360.

SCHAEFER, FRANK

State Action on the Domestic Production Activities Deduction.
05:567.

Tax Clinic

ACKERMAN, JOEL E.

October 05:586.

BAKALE, ANTHONY S.

August 05:454.

GARAY, MARK

March 05:130.

GOTTSCHALK, STEFAN

February 05:66.

KAUTTER, DAVID J.

January 05:6.

KELLY, TERENCE

May 05:254.

KOPPEL, MICHAEL D.

December 05:722.

LERMAN, JERRY L.

April 05:190.

MADDEN, DAVID

June 05:318.

OCONNELL, FRANK J., JR.

September 05:518.

REILLY, KEVIN F.

November 05:658.

SCHWARZ, MEL

February 05:66.

SMITH, ANNETTE B.

July 05:386.

Tax Education

(For Campus to Clients entries, see p. 779)

NELLEN, ANNETTE

February 05:115.
May 05:299.

CARR, JANICE

Help Wanted: Tax and Accounting Educators. 05:115.

NELLEN, ANNETTE

How to Incorporate Tax Reform into Tax Courses. 05:299.

Tax Practice & Procedures

ELY, MARK H.

January 05:48.
April 05:232.
July 05:436.
October 05:640.

BAUMAN, CHRISTINE C.

TAP: Mission and Methods. 05:436.

BRENNAN, JAMES E.

AJCA Penalties for Noncompliance with Reportable Transaction Regs. 05:232.

BUSCHEL, STEPHEN R.

Circular 230: New Rules on Written Tax Advice. 05:641.

CHASSMAN, NANCY

AJCA Penalties for Noncompliance with Reportable Transaction Regs. 05:232.

CRYAN, THOMAS

New Procedure for the Suspension of Interest on Underpayments. 05:437.

DOUGHERTY, JAMES A.

New IRS InitiativeCompliance Assurance Process (Real-Time Audit). 05:49.
New Procedure for the Suspension of Interest on Underpayments. 05:437.
PFA ProgramAn Increasingly Useful Tool for Taxpayers. 05:236.

FIEDELMAN, RONALD S.

Digest of Recent IRS Initiatives and Realignments. 05:640.

MICHNAY, RUTH ANN

IRS and AICPA Collaborate on OIC Program. 05:48.

PARKER, KENNETH M.

SE Tax of LLC Members. 05:644.

SNOW, DANNY

Sec. 179 Recapture and SUVs. 05:438.

SYLVIA, SHARLENE M.

New IRS InitiativeCompliance Assurance Process (Real-Time Audit). 05:49.
New Procedure for the Suspension of Interest of Underpayments. 05:437.
PFA ProgramAn Increasingly Useful Tool for Taxpayers. 05:236.

Tax Practice Management

HOLUB, STEVEN F. and T. CHRIS MUIRHEAD

March 05:170.
June 05:358.
September 05:563.

HOLUB, STEVEN F. and JEFFREY A. PORTER

December 05:762.

MAIDA, JOSEPH C.

IRS Launches Enhanced E-Services. 05:358.

MANTEGANI, BARBARA J.

Pro-Bono Tax AssistanceCPAs Wanted All Year Long. 05:762.

PORTER, JEFFREY A.

Pro-Bono Tax AssistanceCPAs Wanted All Year Long. 05:762.

SCHAEFER, RENE C.

Reportable TransactionsWhat Tax Advisers Need to Know. 05:563.

VALENTI, STEPHEN P.

Technology QC Issues in Tax Practice. 05:170.

Web Browsing

SCHMIDT, DENNIS and WILL YANCEY

October 05:646.

Subject Index

Accounting Methods & Periods

AJCA provisions

bonus depreciation on aircraft. 05:68.

FAS No. 109 implications. 05:255.

FASB proposed guidance. 05:65.

leasehold improvements. 05:7.

motorsport racetracks. 05:9.

organizational expenditures. 05:8.

professional sports franchises. 05:9.

restaurant property. 05:7.

Sec. 179. 05:8.

start-up expenditures. 05:8.

utility grading costs. 05:7.

Debt issuance costs. 05:130.

FASB exposure draft on uncertain tax positions. 05:612.

Installment sales. 05:454.

Intangibles capitalization. 05:253, 318.

Inventory. 05:320.

Schedule M-1 adjustments. 05:586.

Simplified capitalization methods. 05:649.

Tax contingency reporting. 05:254.

Agriculture

Cooperatives of foreign members. 05:324.

Consolidated Returns

AJCA, consolidated return regulatory authority. 05:9.

Calculating loss disallowance. 05:132, 386.

Debt capitalization. 05:389.

Dual consolidated loss regs. 05:658.

Stock basis adjustments. 05:388.

Corporations & Shareholders

AJCA provisions

divisive reorganizations, transfers to creditors. 05:12.

nonqualified preferred stock. 05:12.

Sec. 338(h)(10), estimated taxes. 05:12.

Sec. 357(c). 05:13.

AMT. 05:66.

BILs. 05:518.

Exchange of net value requirements for nonrecognition. 05:253.

Expanded A reorg. requirements. 05:257.

Recent developments. 05:32.

Sale or exchange to corporation. 05:51.

Schedule M-3. 05:189, 404, 452.

Sec. 382, brotherly stock sale. 05:256.

Stock bonuses to transfer control. 05:305.

Stock transfer to creditors. 05:190.

Credits Against Tax

Low-income housing credit. 05:556.

R&E credit. 05:136.

alternative incremental credit. 05:722.

Depreciation

Bonus depreciation on aircraft. 05:6, 68.

Home office. 05:573.

Land preparation costs. 05:276.

Leasehold improvements. 05:7.

Motorsport racetracks. 05:9.

Professional sports franchises. 05:9.

Recapture. 05:418, 480.

Restaurant property. 05:7.

Sec. 179. 05:8, 438.

Start-up expenditures. 05:8.

Truckstop facilities. 05:443.

Utility grading costs. 05:7.

Employee Benefits & Pensions

Administrative services liability. 05:588.

Current developments. 05:684, 752.

Defined-benefit plan. 05:571.

Divorce and transfers of NQSOs and deferred compensation rights. 05:191.

ESOP redemption payment. 05:326.

HRAs for former employees. 05:121, 710.

MRAs and qualified plans. 05:773.

Post-AJCA nonqualified deferred compensation plans. 05:69.

Reporting stock-based compensation. 05:589.

Retirement plan COLA. 05:720.

Roth 401(k). 05:584, 723, 725.

RMDs, rollovers. 05:177.

Sec. 162(m) limits. 05:139.

Stock options. 05:456.

Estates, Trusts & Gifts

Charitable gifts. 05:520.

boats, planes, automobiles. 05:657.

Disclaimer

private foundations. 05:459.

vow of poverty. 05:196.

Donor-managed investment account technique. 05:193.

Equitable apportionment of estate tax. 05:775.

FLPs

Bongard. 05:476.

indirect gift trap. 05:259.

Sec. 2036(a). 05:585.

Strangi appeal. 05:574, 661.

GST tax

deemed allocations, election out. 05:64.

exemption allocation. 05:517.

Form 8892. 05:316.

gift tax returns. 05:192.

indirect skip regs. on exemption allocation. 05:738.

predeceased parent rule. 05:64.

Investment advisory fees. 05:516.

Marital deduction. 05:261.

Recent developments. 05:550.

Sec. 643 final regs. 05:280, 733.

Special needs trusts. 05:40.

Spousal waiver, CRTs. 05:385.

Third-party trusts. 05:490.

Exempt Organizations

Intermediate sanctions. 05:424.

Nonprofit organizations

reform. 05:252.

reporting controls. 05:264.

Partnership investment reporting. 05:392.

Expenses

Aircraft

entertainment travel, corporate aircraft. 05:452.

personal use. 05:522.

repairs, capitalize. 05:328.

Demolition payments. 05:663.

Fines and penalties. 05:392.

Interest, see Interest Income & Expense.

Investment banking fees. 05:521.

Legal fees, governmental investigations. 05:341.

Reasonable compensation. 05:576.

Sec. 179 deduction. 05:460.

Sec. 183 and horse owners. 05:592.

Stock options and cost-sharing agreements. 05:656, 711.

Taxes and damages calculations. 05:614.

T&E substantiation. 05:265.

mileage rates. 05:657.

Foreign Income & Taxpayers

Canada. 05:462.

ETI exclusion repeal. 05:13.

Expatriate, death. 05:196.

Financial accounts, reporting and disclosing. 05:346.

Forms of overseas operations. 05:156, 214.

FTCs

baskets. 05:76.

interest expense allocation and

apportionment options. 05:76.

supercharged. 05:80.

Partnerships

FTC allocations, temporary regs. 05:354.

PFICs and QEFs. 05:330.

Repatriation dividend deduction. 05:78.

Sec. 267(f), deferral of currency loss. 05:393.

Transfer-pricing rules. 05:266.

Germany. 05:464.

Gains & Losses

AMT and long-term capital gain rates. 05:544.

Equipment leasing losses. 05:594.

Insurance agency termination payments. 05:507.

Like-kind exchange

common problems and solutions. 05:204.

related-party. 05:188.

Profit motive. 05:369.

Sec. 384, use of NOLs. 05:394.

Straddle rules, post-AJCA. 05:334.

Gross Income

Claim-of-right doctrine. 05:197.

Contingent fees. 05:178.

Disability pay. 05:307.

Kiddie tax. 05:664.

Lessee construction allowances. 05:598.

Lottery payments. 05:370.

Sec. 199

construction-related gross receipts. 05:594.

domestic production activities. 05:339.

Structured settlements. 05:26.

Tool allowances. 05:713, 726.

Individuals

AJCA, significant individual provisions. 05:92.

Below-market loans to children. 05:175.

Clergy housing allowances. 05:82.

Divorce planning with trusts. 05:708.

Employer-employee relationships. 05:142.

Energy Policy Act of 2005. 05:666.

HSA eligibility. 05:371.

Hurricane Katrina casualty losses. 05:720.

Innocent spouse. 05:53.

Military personnel. 05:87.

Personal residence gain exclusion. 05:525.

dual-use property and Sec. 1031. 05:602, 678, 746.

Sales tax deductions. 05:128.

Social Security benefit reductions. 05:444.

Stock rights and warrants. 05:440.

Tax Freedom Day. 05:129.

2005 inflation adjustments. 05:65.

WFTRAs individual income tax provisions. 05:98.

Interest Income & Expense

Investment interest deduction and qualified dividends. 05:317.

Insurable interest. 05:774.

Legislation

AJCA. 05:4, 6, 7, 8, 9, 12, 13, 14, 16, 18, 19, 20, 22, 23, 68, 69, 76, 78, 80, 85, 92, 148, 232, 334, 339, 452, 518, 522, 534, 594, 626, 657, 678, 684, 694, 724.

Energy-efficient buildings. 05:585.

Energy Policy Act of 2005. 05:666, 674.

Hurricane Katrina. 05:728.

Internet taxes, extended moratorium. 05:64.

Safe, Accountable, Flexible, Efficient Transportation Act. 05:674.

SILO. 05:252.

SOA. 05:268.

Tsunami aid, accelerated charitable deduction. 05:128.

WFTRA. 05:98.

LLCs & LLPs

Patent owners. 05:397.

Sole proprietorship, converting from.

05:647.

Small, privately held businesses. 05:24.

Miscellaneous

AICPA proposed business valuation standards. 05:253.

PCAOB rules for tax services. 05:128.

Partners & Partnerships

AJCA provisions

loss transfers, disallowance. 05:14.

organization and start-up expenditures. 05:14.

PTP net income. 05:16.

satisfaction of debt with partnership interest. 05:16.

Sec. 734 basis reduction. 05:16.

At-risk rules. 05:466.

Corporate contributions. 05:119.

Corporate interest limits on partnership debt. 05:398.

Current developments. 05:106.

Elections grid. 05:200.

Foreign partner withholding. 05:526.

Partner, avoiding tax on outside income. 05:366.

Partnership interest for services regs. 05:636.

Partnership liabilities. 05:453.

SILO legislation. 05:252.

TEFRA partnership refund claims. 05:400.

Pensions

See Employee Benefits & Pensions.

Personal Financial Planning

AICPA eldercare services marketing. 05:229.

Estate planning with life insurance. 05:433.

LTC insurance. 05:45.

Practice & Procedures

AJCA, penalties for noncompliance with reportable transaction rules. 05:232.

Auditors and tax work. 05:585.

Chief Tax Officer reporting structures. 05:620.

Circular 230, written tax advice. 05:641.

IRS

compliance initiatives. 05:49, 584, 640.

OIC program. 05:48.

PFA program. 05:236.

SE tax on LLC members. 05:644.

Suspension of interest on underpayments. 05:437.

TAP missions and methods. 05:436.

TEC initiatives. 05:113, 297, 498, 702.

Practice Management

IRS E-Services expanded. 05:316, 358.

Pro-bono services. 05:762.

Reportable transactions. 05:563.

Technology QC issues. 05:170.

Procedure & Administration

Adequate disclosure guidelines. 05:122.

AJCA provisions

accuracy-related penalty for listed and reportable transactions. 05:19.

actions to enjoin tax shelter and reportable transactions. 05:19.

investor list maintenance. 05:20.

penalties

failing to disclose reportable transactions. 05:22.

failing to report interests in foreign financial accounts. 05:23.

on promoters. 05:22.

regulation of individuals practicing before Treasury. 05:23.

SOL for unreported listed transactions. 05:23.

substantial understatement penalty for nonreportable transactions. 05:19.

tax shelter exception to confidentiality privileges. 05:23.

tax shelter registration. 05:18.

CARDS transactions. 05:188.

Disaster relief. 05:584, 657, 728.

Disregarded entities, excise and employment tax liability. 05:721.

E-filing

requirements. 05:252.

survey. 05:295.

Estimated tax payments. 05:728.

FICA, financial hardship defense. 05:180.

Form W-4 exemptions. 05:471.

Hurricane Katrina. 05:584, 657, 720.

IRS

data book statistics. 05:317.

overpayment of interest. 05:403.

tax enforcement. 05:541.

National Research Program. 05:516.

Penalty suspension period for amended returns. 05:245.

Reimbursement of parking expenses. 05:54.

Reportable transaction guidance. 05:84, 241, 242.

Sec. 1441 voluntary compliance program. 05:142.

SOA, accounting for income taxes. 05:268.

Tax Court, special trial judge report. 05:308.

U.S. reportable requirements for Canadian RRSPs/RRIFs. 05:146.

Real Estate

AJCA provisions. 05:85.

Capital gains on development property. 05:606.

Dealer status. 05:508, 530.

Like-kind exchanges and QIs. 05:667.

Rental real estate professionals. 05:528.

S Corporations

Bankruptcy. 05:56.

Cash basis for certain expenses paid to

shareholders. 05:239.

Coordinated issue paper. 05:384.

Current developments. 05:626, 694.

ESBTs. 05:532.

Estate freeze special valuation rules. 05:505.

Financial institutions seeking S status. 05:534.

IRS scrutiny. 05:517.

Reasonable compensation and SE taxes. 05:608.

Redemption treatment. 05:272.

Salary limits. 05:669.

Sale, stock vs. assets. 05:770.

Special Industries

Captives. 05:406.

Royalty trusts. 05:484.

Qualified zone academy bonds. 05:538.

State & Local Taxes

California, insurance company DRD. 05:143.

Current corporate income tax developments. 05:162, 221.

Deductions, related-party interest and intangible expenses. 05:286.

Domestic production activities deduction. 05:567.

Massachusetts, employee vs. independent contractor. 05:730.

Nexus, proposed legislation. 05:475.

Permanent sales tax deduction. 05:189.

Streamlined Sales Tax Project. 05:765.

Substance-over-form doctrine. 05:610.

Telecommuters. 05:360.

Texas, Home Interiors decision. 05:672.

Tax Education

Pro-bono services. 05:500.

Tax and accounting educators. 05:115.

Tax policy. 05:704.

Tax reform, curriculum. 05:299.

Tax Policy

AICPA tax reform report. 05:720.

Social Security white paper. 05:253.

Technology

VoIP. 05:274.