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	Table of Contents July 2004

Asterisks indicate items in the Tax Clinic department.

Consolidated Returns
	*	Intercompany Transaction and Loss Disallowance Relief Provisions

Credits Against Tax
	*	Continuing Uncertainty on Research Credit Definition of Gross Receipts

Employee Benefits & Pensions
		HSA Eligibility for FSA and HRA Participants

Estates, Trusts & Gifts
		The Uglier Side of the UGMA
		The Intricacies of Special-Use Valuation by Thomas Zupanc, Carol B. Gaumnitz and Bruce R. Gaumnitz
		FLP Transfers Were Bona Fide

Exempt Organizations
	*	Executive Compensation Reporting and Taxation of Automatic Excess-Benefit Transactions

Expenses
	*	Retention of the Separate and Distinct Asset Test in the Final Intangible Asset Regs.
		Truckers Expense Allowance Subject to 50% Deduction Limit

Gains & Losses
	*	Proposed Notional Principal Contract Regs. Address Contingent Payments and Character
	*	Sec. 1271(a)A Pitfall for Unwary Corporate Creditors
		Using a Like-Kind Exchange to Avoid Gain Recognition

Gross Income
		Class Actions and the Attorneys Fees Conundrum by Robert W. Wood and Dominic L. Daher

LLCs & LLPs
		LLC Members and Employment Taxes
	*	Series LLC Tax Issues

Personal Financial Planning
		AICPA ElderCare/PrimePlus Services (Box)
		Private Annuities as an Aid to Medicaid Eligibility

Practice & Procedures
		An Analysis of SSTS Interpretation No. 1-2 (Part 1) by John C. Gardner, Bruce E. May and Roger Reinsch
		New IRS Compliance Initiatives
		Office of Taxpayer Burden Reduction
		ITINsExceptions and Questions
		The Downsized EITC Certification Pilot Program

Procedure & Administration
		Small Business Compliance Tools
	*	When Must the IRS Pay Interest on Refunds?

Special Industries
	*	Using Captives to Manage Risk

State & Local Taxes
	*	Accrual of California Franchise Tax Liabilities

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