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Gains & Losses
Abandoned
contract. 98:14.
or worthless assets. 93:804; 98:295.
Abandonment
partnership interest. 91:693; 93:97.
Acreage, sales of multiple parcels and Sec. 121. 98:83.
Allocating investments to maximize after-tax return. 99:328.
Allocation of purchase price on asset acquisition. 97:356.
Amount realized on foreclosure sale. 99:64.
Annuity contract in Sec. 1035 exchange. 94:283; 99:396.
Appreciated property
determining corporation's gain on sale. 95:515.
Assumed liabilities, basis increase for. 99:769.
At-risk rules
loss limitations. 99:700.
"new" activities. 91:128.
real estate. 91:92.
Attribution rules. 93:301.
Bad loans
deductions for. 90:406.
Bank
loan loss reserves and NOL carrybacks. 95:186.
mutual fund losses. 99:814.
Bankruptcy
abandonment of property. 90:553.
E&P issues. 93:709.
situations. 91:454.
Bargain purchases of assets. 90:494.
Basis for loss purposes. 98:646.
Basis of property inherited by spouse. 95:754.
Basis reduction for cancellation of debt. 98:152, 222; 99:148.
Boot received in acquisitive reorganizations. 96:248, 770.
Built-in gains
discount. 99:308, 310.
rules. 90:388.
Built-in loss benefits. 92:164.
Cancellation of bankrupt company stock. 97:529.
Cancellation of indebtedness
basis reduction proposed regs. 97:357.
stock received. 90:150.
Capital gain and loss rules
after TRA '97. 97:748, 760; 98:398.
after IRSRRA '98. 99:310.
Capital gain distributions from CRTs. 99:90.
Choice of entity issues. 99:557.
Closing of books election. 95:80.
COD income on sale of property. 99:276.
COD rules for real estate. 95:84.
Commodity dealers
hedging transactions. 92:695.
Commodity swaps. 91:453.
Condemnations. 90:86.
Conduit financing entities. 97:277.
Contingent debt
proposed regs. 95:215.
Contingent liabilities. 99:769.
Contribution carryforwards in AMT. 96:74; 97:81.
Conversion of C corp. to exempt organization. 97:211.
Conversion transactions
new Sec. 1258. 93:691.
proposed regulations. 95:117.
Converting debt to Sec. 1244 stock. 90:764.
Cooperative apartment shares. 95:122.
Corporation's assumption of shareholder's obligation to
provide replacement securities. 95:514.
Cottage Savings final regs. 96:460; 97:83.
Covenants not to compete. 90:684; 93:426.
C stock sales. 98:822.
Debt discharge income
and NPC assignments. 98:456.
generally. 90:648.
in bankruptcy. 90:300.
Debt modification. 92:98; 93:300; 96:460.
Debt securities
renegotiating. 90:431.
Debt transactions. 94:131.
Deferred like-kind exchanges. 90:756; 93:32.
and installment sales. 94:380; 562.
Depreciated securities. 91:245.
Developer status
corporation wholly owned by partners. 93:101.
Discarded tenant improvements. 93:180.
Disaster
losses. 97:646.
proceeds. 95:310.
Divorce
personal residence. 93:665; 97:668, 669.
redemption of joint property. 93:576.
stock redemption. 94:253.
Economic substance doctrine. 99:16.
Employer's gain or loss on resale of employee's home.
90:458, 731.
Empowerment zone employment credit. 96:344.
Environmental
cleanup costs. 94:741.
regs. and involuntary conversions. 97:82.
ESOP rules. 90:235.
Estate's abandonment of assets to debtor. 92:518.
Exchange of options in acquisition. 91:376.
Exchanges of partnership interests. 92:101.
Family business consulting. 93:3.
FASITs. 97:139.
Financial instruments
taxing time value of money. 95:245.
Foreclosure sale
avoiding capital gain on. 95:428.
recourse mortgage. 92:697.
Foreign currency losses from loans. 93:307.
Foreign currency transactions. 93:238.
Forward contracts
currency. 91:451.
Forward conversion of securities. 93:243.
Franchise costs. 92:814.
Garnished bank accounts. 98:728.
Goodwill. 91:602.
Hedging transactions. 91:795.
final regs. 94:579; 95:94, 131.
in consolidated groups. 96:197.
temporary and proposed regs. 94:301; 95:94, 131.
Hobby vs. activity engaged in for profit. 95:161; 95:446.
Inflation-indexed debt instruments.97:143.
Insolvency. 91:579; 92:158; 99:158.
Insolvency and change of ownership. 92:451.
Installment sales
basis. 98:299.
electing out. 95:444.
post-TRA '97. 98:85.
unrecaptured Sec. 1250 gains. 99:701.
Insured business losses. 92:116.
Investment planning. 91:422.
Investor vs. trader. 90:565.
Involuntary conversions. 92:693; 99:769.
Like-kind exchanges. 90:216, 456, 571, 572, 578; 91:88,
90; 96:534; 97:276, 279, 716; 98:162, 298, 531, 532; 99:89.
Liquidation tax on C to S conversions. 97:212.
Loss carryovers on real estate. 96:606.
Mortgage repayment
currency fluctuations. 91:241.
Multiple asset exchanges. 91:636.
Multiple entities
avoiding U.S. withholding. 94:362.
NOLs.
adjusting carryover from closed year. 95:665.
bankruptcy exception to limits. 91:437.
carryback in calculating bad debt deduction. 95:663.
carryback of passive losses. 94:277.
carryback waiver election. 92:128.
carrybacks for thrifts. 90:344; 92:93.
carryforward limitations. 91:759, 835; 92:411.
election to relinquish NOL carrybacks. 94:387.
from regulatory compliance costs. 97:55.
"working capital" contribution used to increase
carryforward. 95:666.
Nonidentified hedging transactions. 97:417.
Nonrecourse debt. 97:186, 213.
Options. 93:350.
Planning during recession. 91:662.
Planning with low interest rates. 93:362.
Principal residence
destroyed in involuntary conversion. 96:510.
employer's loss on resale. 90:573.
facts and circumstances test for Sec. 121 exclusion. 98:506.
multiple dispositions. 90:301, 424.
planning for in divorce and remarriage. 93:665; 97:90.
pre-existing mortgages and replacement residence cost. 96:447.
rental. 90:533.
sale. 94:713.
sale after death. 97:90.
sale in bankruptcy. 93:430; 98:534.
sale in divorce setting. 92:795; 95:716, 717; 97:90.
sale upon marriage. 94:450; 97:90.
temporary conversion. 94:107, 742.
TRA '97 gain exclusion rules. 97:758; 98:116, 232.
transfer on divorce or separation. 90:772.
vacating under divorce settlement. 96:709.
Purchase price adjustments. 94:79.
Qualified small business stock. 98:800; 99:15.
Qualified student loan bonds. 90:191.
Reacquisition of real property. 98:14.
Real estate
environmentally contaminated, retirement of. 95:278.
post-rezoning decrease in value. 98:223.
post-TRA'97 sales. 98:224.
reacquisition. 98:14.
rentals. 90:533.
subdividers. 91:656.
Receivables as cash equivalents. 92:160.
Recognition
gain, but not loss. 91:508.
REIT opportunities. 93:427.
Related-party transactions. 94:246; 97:276.
Rental of
residence. 90:533.
timeshares as trade or business. 97:626.
Reorganizations involving QSBS. 95:349.
Rescission. 90:95; 99:314.
Restricted stock. 91:301.
Retirement home occupancy. 90:556.
Reverse exchanges. 92:572; 93:28.
Sale between partnership and corporation
owned by same individuals. 92:558.
Sale-leaseback vs. reverse mortgage. 92:360.
Sale of
assets
    failed bank acquisition. 91:100.
life insurance contract by terminally ill insured. 95:62.
S stock for oil, gas or mining corporations. 96:729.
Sale of prior residence by divorced spouse. 94:646.
Seagram's stock redemption plan. 95:549.
Sec. 267 related parties. 91:390.
Sec. 351 transfer of encumbered property. 97:280.
Sec. 382
acquisitions to avoid tax. 90:659.
option rule. 90:158; 92:723.
"options." 92:351.
order of events. 94:354.
ownership changes. 94:86.
Sec. 1038 avoidance. 96:34.
Sec. 1042
failure to file election deferral. 95:489.
Sec. 1202 stock. 97:483; 99:556.
Sec. 1244. 91:659; 93:786; 95:380, 616; 96:663.
Secured property, assignment of sales proceeds. 98:153.
Seller-paid points deduction. 94:344, 572, 614.
Shareholder note's effect on contribution of encumbered assets. 98:504.
Shareholder's compensatory transfer of stock to employees. 98:20.
Short sales against the box. 96:345; 99:246.
Software proposed regs. 97:145.
Special-purpose entities and tax-free exchanges. 98:84; 99:90.
Specified liability losses. 95:345; 96:75; 97:528; 99:316.
Stock, bond and mutual fund ownership. 94:550.
Stock contributed to charity shortly before merger. 99:372, 438.
Stock redemptions
pursuant to divorce. 94:469
Seagram's. 95:549.
using property. 94:578.
Stock sales
basis adjustments. 97:756.
cash basis taxpayers. 94:434.
Straddles. 95:380.
Subsequent events
effect on option deemed exercise. 94:366.
SSBICs. 94:21.
Subdivided real estate. 90:641.
Tax-free exchanges
life insurance policies. 92:26.
like-kind exchanges
    tightening. 90:533.
Taxpayer Relief Act of 1997. 98:18.
Tender offer as option. 92:463.
Tentative carrybacks for corporations. 90:426; 96:763.
Terminally ill insured
sale of life insurance contract. 95:62.
Theft losses. 98:68.
Trader status. 92:517.
Transaction values for U.S. Customs. 93:244.
Treatment of
closed-year NOL. 95:347.
NOLs and AMT NOLs from same year. 95:315.
Variable annuities. 99:225.
Worthlessness. 92:198.
Worthless stock
holding company. 90:339.
timing of deductions. 96:730.
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