Author Index

Twelve Months Ended December 2006

BAKKE, DON W.

Corporations & Shareholders: Significant Recent Developments. 06:100.

BEASLEY, MARK S.

Brainstorming to Identify and Manage Tax Risks. 06:158.

BOUCHER, KAREN J.

State & Local Taxes: Current Corporate Income Tax Developments. (Part I) 06:170. (Part II) 06:232.

BROWN, STEVEN J.

Checklists for Determining Whether a Trust Is a Valid S Shareholder. 06:152.

BURILOVICH, LINDA

Planning Techniques to Avoid the Reclassification of Shareholder Debt as Equity. 06:708.

BURTON, HUGHLENE A.

Partners & Partnerships: Current Developments. 06:108.
S Corporations: Current Developments. (Part I) 06:605. (Part II) 06:666.

CHRISTENSEN, ANNE L.

Recordkeeping Requirements and the Consequences of Lost, Destroyed or Stolen Records. 06:464.

COOK, ELLEN D.

The AICPA Looks at the Uniform Definition of a Child. 06:591.

EIDE, BARBARA J.

Amendments to Circular 230. (Part I) 06:24. (Part II) 06:90.

ELLENTUCK, ALBERT B.

For “Case Study,” see the cover of each issue.

FITZPATRICK, ARLENE

Allocation and Apportionment of Expenses for Sec. 199 Purposes. 06:336.

GARDNER, JOHN C.

Amendments to Circular 230. (Part I) 06:24. (Part II) 06:90.

GODFREY, HOWARD

Below-Market Loans May Have Unexpected Tax Results. 06:350.
The Post-TIPRA Foreign Earned Income and Housing Exclusions for Individuals. 06:716.
Withholding Requirements for Income Allocated to Foreign Partners (Part I). 06:534. (Part II) 06:597.

GOLDSTEIN, BENSON S.

Mandatory E-Filing for Large Corporations and Exempt Organizations. 06:22.

GORIN, STEVEN B.

Checklists for Determining Whether a Trust Is a Valid S Shareholder. 06:152.

GUINN, ROBERT

Below-Market Loans May Have Unexpected Tax Results. 06:350.

HIBSCHWEILER, ARLENE M.

Can Your Tax Client (or You) Go to Jail? (Part I) 06:216. (Part II) 06:280.

HOWELL-SMITH, LAURA

Checklists for Determining Whether a Trust Is a Valid S Shareholder. 06:152.

HYMAN, MARC A.

Checklists for Determining Whether a Trust Is a Valid S Shareholder. 06:152.

JENKINS, J. GREGORY

Brainstorming to Identify and Manage Tax Risks. 06:158.

JONES, PAULA M.

The Effect of Residency in International Estate Planning. 06:527.

KARLINSKY, STEWART S.

S Corporations: Current Developments. (Part I) 06:605. (Part II) 06:666.

KARNES, ALLAN

Treatment of Community Income for Spouses Living Apart. (Part I) 06:164. (Part II) 06:224.

KARNES, DARLA

Treatment of Community Income for Spouses Living Apart. (Part I) 06:164. (Part II) 06:224.

KASTANTIN, JOSEPH T.

Amendments to Circular 230. (Part I) 06:24. (Part II) 06:90.

KEHOE, DANEA M.

Is a Single-Employer Welfare Benefit Plan Appropriate for a Small Business? 06:86.

KENNY, WILLIAM J.

Recordkeeping Requirements and the Consequences of Lost, Destroyed or Stolen Records. 06:464.

KORB, PHILLIP J.

How Reduced Rates for Capital Gains and Qualified Dividends Affect the FTC. 06:414.

KRAAY, VICKIE

Allocation and Apportionment of Expenses for Sec. 199 Purposes. 06:336.

KRUMWIEDE, TIM

Substantiation Rules for Charitable Gifts. 06:724.

LAFFIE, LESLI S.

For “News Notes,” see the cover of each issue.

LAGARDE, STEPHEN

The Pension Protection Act of 2006—a Comprehensive Reform Package. 06:650.

MALMGREN, EDWARD

Below-Market Loans May Have Unexpected Tax Results. 06:350.

MARES, MICHAEL E.

Individuals: Current Developments. 06:292.

MASON, J. DAVID

Calculating Depreciation on a Like-Kind Exchange or an Involuntary Conversion. 06:42.

MATTSON, ANDREW M.

International Provisions of TIPRA. 06:400.

MCNAMARA, LAWRENCE H.

Tax Accounting Issues for Foreign Trusts. (Part I) 06:344. (Part II) 06:408.

MONTGOMERY, GWENDOLYN A.

Tax Consequences to Investors of Broker Fraud and Theft. 06:36.

MORRIS, RICHARD C.

The GWE, a (Not So New) Tax Exclusion Worth a Look. 06:286.

NASH, CLAIRE Y.

Recognition of “Debt Modification Income” Following Consumer Bankruptcy Reform. 06:658.

O’DRISCOLL, DAVID

For “Tax Trends,” see the cover of each issue.

ORBACH, KENNETH N.

Checklists for Determining Whether a Trust Is a Valid S Shareholder. 06:152.

PARKER, JAMES

Recognition of “Debt Modification Income” Following Consumer Bankruptcy Reform. 06:658.

PONDA, SHONA

State & Local Taxes: Current Corporate Income Tax Developments. (Part I) 06:170. (Part II) 06:232.

ROLLINSON, MARGIE

Allocation and Apportionment of Expenses for Sec. 199 Purposes.
06:336.

ROOD, DEBORAH K.

State and Local Tax Resources from the AICPA. 06:525.

SALMON, SCOTT

Treatment of Community Income for Spouses Living Apart. (Part I) 06:164. (Part II) 06:224.

SATCHIT, VINU

Estates, Trusts & Gifts: Significant Recent Developments in Estate Planning. 06:540.

SAWYERS, ROBY B.

Brainstorming to Identify and Manage Tax Risks. 06:158.
Estates, Trusts & Gifts: Significant Recent Developments in Estate Planning. 06:540.

SCHWIETERMAN, JILL

Allocation and Apportionment of Expenses for Sec. 199 Purposes.
06:336.

SHERR, EILEEN

International Provisions of TIPRA. 06:400.

SIGLER, JOHN N.

How Reduced Rates for Capital Gains and Qualified Dividends Affect the FTC. 06:414.

SINGER, STUART R.

Deferred Compensation for Executives under Sec. 409A. (Part I) 06:402. (Part II) 06:476.

SULLIVAN, NEIL A.J.

The Post-TIPRA Foreign Earned Income and Housing Exclusions for Individuals. 06:716.

TRAUM, SYDNEY S.

Checklists for Determining Whether a Trust Is a Valid S Shareholder. 06:152.

VERMEER, THOMAS E.

How Reduced Rates for Capital Gains and Qualified Dividends Affect the FTC. 06:414.

WALKER, DEBORAH

Is a Single-Employer Welfare Benefit Plan Appropriate for a Small Business? 06:86.
The Pension Protection Act of 2006—a Comprehensive Reform Package. 06:650.

WITNER, LARRY

Substantiation Rules for Charitable Gifts. 06:724.

WOOD, ROBERT W.

The Advantages of Selling Appreciated Assets via a Structured Sale. 06:472.
The GWE, a (Not So New) Tax Exclusion Worth a Look. 06:286.

WRIGHT, KATHLEEN

S Corporations: Current Developments (Part II). 06:666.

ZAITZEFF, ELIZABETH

Corporations & Shareholders: Significant Recent Developments. 06:100.

ZWICK, GARY A.

Tax Consequences to Investors of Broker Fraud and Theft. 06:36.

Campus to Clients

NELLEN, ANNETTE

February 06:116.
May 06:304.
August 06:486.
November 06:678.

EIDE, BARBARA J.

Integrating Circular 230 into the Tax Curriculum. 06:486.

GARDNER, JOHN C.

Integrating Circular 230 into the Tax Curriculum. 06:486.

KASTANTIN, JOSEPH T.

Integrating Circular 230 into the Tax Curriculum. 06:486.

MAGRO, ANNE M.

Evaluating Career and Life from a “7 Habits” Perspective. 06:304.

PURCELL, THOMAS J.

Professional Committee Service—A Win-Win Strategy. 06:678.

TURNER, MARLENE E.

Rising Expectations in Business Education. 06:116.

D.C. Currents

HOOPS, JEFFREY R.

Tax Section’s Strategic Plan. 06:674.

PURCELL, THOMAS J., III

TEC Initiatives. February 06:114.
TEC Initiatives. May 06:300.
TEC Initiatives. August 06:484.

On the Bookshelf

FINK, PHILIP R.

March 06:182.
June 06:366.
September 06:555.
December. 06:740.

Personal Financial Planning

MINKER, MARK J.

January 06:48.
April 06:240.
July 06:420.
October 06:613.

EISENBERG, MICHAEL M.

The PFS Designation Adds Value. 06:613.

FOHN, DICK

Tax Advice or Investment Advice: Where Is the Line? 06:420.

GRAY, ROBERT L.

Fiduciary Responsibility and Opportunity. 06:240.

PRIMOFF, WALTER M.

Fiduciary Responsibility and Opportunity. 06:240.

SCHULMAN, MICHAEL DAVID

A Primer on Annuities. 06:48.

State & Local Taxes

SALMON, SCOTT

June 06:361.
September 06:550.
December 06:736.

BROOKNER, BRAD J.

Sweeping Texas Franchise Tax Changes: The Margin Tax. 06:550.

BROWN, RUSSELL D.

Sweeping Texas Franchise Tax Changes: The Margin Tax. 06:550.

MCGAHAN, SARAH

Streamlined Sales Tax: Debate Continues on MPU Purchases and the Digital Goods Definition. 06:736.

NICOLAS, KARL

Will the Push for Origin-Based Sourcing Derail SST? 06:361.

Tax Clinic

ACKERMAN, JOEL E.

October 06:570.

BAKALE, ANTHONY S.

August 06:446.

GARAY, MARK

March 06:134.

GOTTSCHALK, STEFAN

February 06:74.

KAUTTER, DAVID J.

January 06:6.

KELLY, TERRENCE

May 06:262.

KOPPEL, MICHAEL D.

December 06:694.

METZ, MICHAEL

April 06:198.

O’CONNELL, FRANK J.

September 06:506.

REILLY, KEVIN F.

November 06:634.

SMITH, ANNETTE B.

July 06:382.

VAN LEUVEN, MARY

June 06:318.

Tax Practice & Procedures

ELY, MARK H.

January 06:52.

MILLER, JOHN L.

April 06:243.
July 06:426.
October 06:615.

BLOOM, AARON

GO Zone Act Provisions for Hurricane Victims. 06:248.

CAPLAN, ROBERT M.

New OIC 20% Partial Payment Requirement Could Backfire. 06:615.

CRYAN, TOM

Changes to the Interest Suspension Rules Contained in the GO Zone Act. 06:243.

GANSLER, JILL

IRS Help Is Just a Click Away. 06:616.

KEENAN, JOHN R.

Managing the Interplay between a Partnership and Its Partners’ Statutes of Limitations. 06:55.
Changes to the Interest Suspension
Rules Contained in the GO Zone Act. 06:243.
Government Ends Long-Distance Phone Excise Tax Dispute. 06:428.

MAGIN, ELIZABETH

Government Ends Long-Distance Phone Excise Tax Dispute. 06:428.

MICHNAY, RUTH ANN

Representing Taxpayers and Withdrawing from Representation. 06:52.

NOLAN, DEBORAH M.

LMSB Realigns Key Management Personnel for Greater Efficiency. 06:244.

PARKER, KENNETH M.

Accounting for Casualty Losses during a National Disaster. 06:58.

SILVIA, SHARLENE M.

Government Ends Long-Distance Phone Excise Tax Dispute. 06:428.

SIMMENS, TODD

IRS Treats Protective Disclosures Inconsistently. 06:426.

SNOW, DANNY

Tax Prepayments—Advance Payments or Deposits Under Blom? 06:617.

STIFF, LINDA

IRS Compliance Studies Aim for Fairness. 06:429.

WILSON, CHASTITY

Managing the Interplay between a Partnership and Its Partners’ Statutes of Limitations. 06:55.

YUSKEWICH, J. MATTHEW

IRS Initiative for Private Debt Collection. 06:54.

Tax Practice Management

HOLUB, STEVEN H.

March 06:177.
June 06:358.
September 06:547.
December. 06:732.

PORTER, JEFFREY A.

March 06:177.
June 06:358.
December. 06:732.

ECKELKAMP, JOSEPH T.

Divesting Clients Wisely. 06:358.

HERMAN, HOWARD

Document Retention. 06:177.

LEY, BARBARA A.

Document Retention. 06:177.

MENDLOWITZ, EDWARD

Complete Pre-Year-End Planning for Select Clients. 06:547.

RISPOLI, VALDA S.

Document Retention. 06:177.

SELLNER, MARK

Document Retention. 06:177.

ZOLLARS, EDWARD, K.

Security Issues When Using Outside Networks. 06:732.

WEBrowsing

SCHMIDT, DENNIS and WILL YANCEY

January 06:60.
April 06:250.
July 06:431.
October 06:619.

Subject Index

Accounting Methods & Periods

Bad debt reserve. 06:694.

Change vs. error. 06:506.

Economic performance, Sec. 263(a) 12-month rule. 06:263.

Gift certificates and gift cards. 06:264.

Inventory

heavy equipment parts. 06:262.

LIFO pooling method. 06:382.

rolling average cost method. 06:196.

trends. 06:198.

UNICAP rules

direct labor costs. 06:318.

errors, omissions and opportunities. 06:321.

Bankruptcy & Insolvency

Automatic stay. 06:494.

Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. 06:4.

Debt modification income. 06:658.

Sec. 403(b) annuity. 06:309.

Charitable Contributions

Conservation contribution disallowed. 06:435.

Hurricane Katrina

charitable deductions. 06:6.

leave-based donations. 06:7.

Substantiation. 06:724.

Consolidated Returns

Controlled services. 06:568.

Loss duplication regulations. 06:384.

Sec. 199 and intercompany transactions. 06:134.

Successor defined. 06:322.

U.K.-U.S. dual consolidated loss agreement. 06:692.

Corporations & Shareholders

Basis of debt obligations. 06:385.

COI requirement. 06:385, 508.

Corporate-shareholder reporting. 06:476.

Current developments. 06:100.

Debt vs. equity. 06:507, 708.

Liquidation-reincorporation. 06:7.

Redemptions and disappearing basis. 06:510.

Statutory mergers. 06:265.

Stock warrants and options. 06:634.

Third-party debt. 06:558.

Times Mirror. 06:200.

UNICAP calculations. 06:201.

Credits Against Tax

Adoption expense, foreign child. 06:571.

Disabled access credit. 06:560.

Home builders. 06:572.

Hurricane Katrina

EIC and refundable child credit. 06:7.

employee retention credit. 06:8.

work opportunity credit. 06:8.

R&E credit

consistent approach. 06:136.

self-constructed assets. 06:9.

2005 developments. 06:139.

Depreciation

Like-kind exchanges and involuntary conversions. 06:42.

Sec. 197. 06:573.

Employee Benefits & Pensions

EPCRS. 06:5.

Home purchase programs. 06:142.

HSAs, employer contributions. 06:132.

Hurricane Katrina

COBRA and HIPAA. 06:11.

health, retirement and disability benefits. 06:11.

IRA, Sec. 401(k) and similar plans. 06:12.

IRA rollover waiver. 06:4.

Mortality tables. 06:72.

Nondeductible contributions. 06:681.

Pension Protection Act of 2006. 06:568, 650.

Roth 401(k). 06:133.

distributions. 06:260.

Sec. 409A

deferred compensation, generally. 06:402.

effective date extended. 06:693.

funding arrangements. 06:388.

prop. regs. 06:132.

PSC retirement arrangements. 06:133.

stock options. 06:202.

valuing stock rights. 06:133.

Sec. 4975 excise tax. 06:574.

Single-employer welfare benefit plan. 06:86.

Stock options and SEC Section 16(b). 06:696.

Estates, Trusts & Gifts

Blended families. 06:505.

Charitable remainder trusts, spousal election. 06:261.

FLPs, valuation discounts. 06:512.

Inherited IRA, transfer to grantor trust. 06:569.

International estate planning, residency. 06:527.

Investment advice fees. 06:744.

LLCs. 06:261.

Marital trusts. 06:514.

Permanent estate tax relief. 06:504.

Private trust company trustee. 06:316.

Recent developments. 06:548.

Schedule K-1 revised. 06:197.

Split-interest charitable deduction. 06:697.

Stock-purchase agreement. 06:188.

Tuition prepayments. 06:317.

Valuation of IRAs. 06:74, 494.

Excise Taxes

Communications excise tax. 06:14.

Insurance excise tax. 06:325.

Long-distance telephone excise tax refunds. 06:428, 576.

Exempt Organizations

Abusive transactions. 06:268.

E-filing requirements. 06:637.

Grants to foreign organizations. 06:635.

Key members’ use of apartment. 06:638.

Lobbying activities. 6:390.

Political elections. 06:316.

Royalty from journal. 06:310.

Expenses

Energy-efficient commercial buildings. 06:204.

Environmental remediation expenses. 06:189.

Feasibility deductions. 06:640.

Interest, see “Interest Income & Expense.”

Meal expenses, 50% limit. 06:683.

Mixed expense reimbursement. 06:370.

Sec. 162(m), commission-based exceptions. 06:144.

Standard mileage rates. 06:72.

Foreign Income & Taxpayers

Check-the-box. 06:206.

Corporate inversions. 06:269, 698.

Currency gap, disposition of foreign subsidiary. 06:210.

Earned income exclusion. 06:716.

Foreign trusts. 06:344.

FTC and reduced rates for capital gains. 06:414.

Government contractors’ exclusion and benefits. 06:205, 209.

NRA tax reporting. 06:579.

Related-person interest regs. 06:253.

Reorganizations and gain recognition. 06:15.

Sec. 901(l) and computer licensing arrangements. 06:76.

Sec. 7874 inversions. 06:698.

Secs. 199 and 965. 06:327.

Subpart F lookthrough rules. 06:641.

Tax accounting issues. 06:408.

Timely filing rule. 06:272.

TIPRA revisions. 06:400.

U.S.-Canada income tax treaty. 06:578.

U.S. reporting for foreign multinationals. 06:391.

Withholding on income allocated to foreign partners. 06:534, 624.

Working abroad. 06:642.

Gains & Losses

AMT. 06:212.

Broker fraud and theft. 06:36.

Capital loss limits. 06:436.

Hurricane Katrina, claiming casualty losses. 06:19.

Intangibles—amortization recapture and sales price allocation. 06:78.

ISOs. 06:450.

Like-kind exchange opportunities. 06:213, 393.

Lottery payments, sale. 06:254, 745.

QSB stock sales. 06:448.

Reorganizations, basis. 06:273.

Residence sale exclusion. 06:132.

Stock acquisition CERT limit on NOL use. 06:392.

Structured sales. 06:472.

Gross Income

Emotional damages. 06:700.

GWE exclusion. 06:286.

Hedge identification and timing rules. 06:146.

NOLs, individuals. 06:148.

Sec. 199

allocation of expenses. 06:336.

final regs. highlights. 06:454.

guidance. 06:274.

“item” defined. 06:79.

Variable prepaid forwards. 06:328.

Individuals

AMT property tax deduction, co-op owner. 06:122.

Bad debts, intrafamily advances. 06:184.

Community income for spouses living apart. 06:164.

Current developments. 06:292.

Education, special needs. 06:645.

Employer relocation payments. 06:72, 702.

Energy tax benefits. 06:196.

Filing extension for taxpayers out of U.S. 06:445.

Hurricane Katrina casualty losses.

disaster relief payments. 06:19.

forgiven debt. 06:19.

low-interest loans. 06:20.

Innocent spouse petition, deficiency notice. 06:310.

IRA

distribution to beneficiary. 06:624.

distributions to charity. 06:701.

recouping nondeductible contributions. 06:681.

Legal fees, above-the-line. 06:644.

NQSOs in divorce. 06:456.

Relocation sales. 06:72, 702.

Tax Freedom Day. 06:73, 633.

Uniform definition of a child. 06:591, 693.

Vacation homes. 06:432.

Vehicle donation rules. 06:330.

Interest Income & Expense

Accrual periods and AHYDO. 06:514.

Below-market loans. 06:350.

Legislation

Bankruptcy Abuse Prevention and Consumer Protection Act of 2005. 06:4, 658.

Gulf Opportunity Zone Act of 2005. 06:243, 248.

Hurricane Katrina. 06:6, 7, 11, 12, 19, 20.

PPA ’06. 06:646, 693.

TIPRA. 06:381, 400, 457, 716.

LLCs & LLPs

Liquidation of member interest. 06:276.

Organizational documents. 06:368.

Out-of-state LLC registration. 06:120.

Renting property to an LLC. 06:622.

Miscellaneous

PCAOB rules approved. 06:444.

Partners & Partnerships

Current developments. 06:108.

Disregarded entities. 06:196.

Nonresident partners’ retirement income. 06:633.

Partner loans. 06:394.

Tiered partnerships, filing obligations. 06:581.

Pensions

See “Employee Benefits & Pensions.”

Personal Financial Planning

Annuities. 06:48.

Fiduciary responsibility and opportunity. 06:240.

PFS designation. 06:613.

Tax vs. investment advice. 06:420.

Practice & Procedures

Accounting for casualty losses. 06:58.

AICPA Tax Section, strategic plan. 06:674.

Appraiser reports. 06:307.

Circular 230 amendments. 06:24, 90.

Deposit vs. payment. 06:617.

Gulf Opportunity Zone Act of 2005. 06:243, 248.

IRS

collection initiative. 06:260.

private debt collection. 06:54.

protective disclosures. 06:426.

LMSB realignment. 06:244.

OIC 20% partial payment. 06:615.

Phishing scheme. 06:260.

Representation and withdrawal. 06:52.

SE tax on LLC members. 05:644.

SOLs—partners and partnerships. 06:55.

TEC initiatives. 06:114, 300, 484.

Telephone excise tax. 06:428.

Practice Management

Brainstorming risks. 06:158.

Divesting clients. 06:358.

Document retention. 06:177.

Security issues, outside networks. 06:732.

Year-end planning. 06:547.

Procedure & Administration

Assessment period extension. 06:692.

Automatic extension procedures. 06:80.

CDP hearings. 06:632.

Collection initiatives. 06:277.

E-filing, large corporations and exempt organizations. 06:22.

Entity-classification elections. 06:396.

Estimated tax payments, corporate. 06:277.

Hurricane Katrina. 06:20.

Innocent spouse. 06:310, 568.

Installment agreement fees. 06:633.

IRS

adequate disclosure guidelines. 06:123.

collection appeals program. 06:648.

frivolous arguments. 06:317.

guidance on AJCA elections. 06:380.

innocent spouse cases. 06:684.

IVES program. 06:692.

protective disclosures. 06:426.

protective refund claims. 06:397.

splitting refunds. 06:632.

NOL refunds. 06:398.

Preparer penalties. 06:5.

Recordkeeping requirements. 06:464.

Reporting damage awards. 06:458.

Revenue rulings as authority. 06:333.

Six-month automatic extension. 06:4.

SOL, payment vs. deposit. 06:561.

Tax crimes. 06:216, 280.

Tax shelter litigation. 06:399.

Teacher’s severance pay. 06:495.

Withholding depositing and reporting. 06:132.

Real Estate

Cost segregation studies. 06:516.

Sec. 1031

exchanges of vacation homes. 06:586.

fractional property interests. 06:584.

S Corporations

Current developments. 06:605, 666.

Electing S status—advantages. 06:490.

Health insurance for S shareholders. 06:587.

Liquidating controlled C corp. 06:251.

QSSTs. 06:705.

QSub election. 06:742.

Trust as valid shareholder. 06:152.

Special Industries

Depository holding companies. 06:214.

Intangibles, valuation. 06:150.

Loan purchase commitment fees as option premiums. 06:82.

Private-equity-fund-owned portfolio corporations. 06:518.

State & Local Taxes

Current corporate income tax developments. 06:170, 232.

E-commerce tax liability. 06:705.

Electronically provided software. 06:83.

Estoppel. 06:605.

Mere delivery. 06:522.

Ohio’s CAT. 06:490.

State and local tax resources from the AICPA. 06:525.

State tax incentives after Cuno. 06:462.

Streamlined Sales Tax Project. 06:361, 736.

Texas margin tax. 06:550.

Tax Education

AICPA financial literacy campaign. 06:693.

Business education. 06:116.

Circular 230. 06:486.

Evaluating career and life. 06:304.

Professional committee service. 06:678.