eGrove (Univ. of Mississippi)

Manning, Robert F.

Tax Adviser 
Volume 13 Issue 3 Article 6 
1982 
thumbtax 
Robert F. Manning 
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thumbtax
Editor: ROBERT F. MANNING, J.D.
Legislation
•
 All
 Savers extension. Sen. Dennis DeConcini  
(D.-Ariz.) has introduced a bill (S.2053) that would
 make the All Savers certificates provisions (Sec.
 128) permanent. The program is now scheduled to
 end Dec. 31,1982. In addition, the bill would double
 the annual amount of interest exempt 
from
 tax (cur ­
rently $1,000 for individual filers and $2,000 for joint
 filers).
IRS rulings, etc.
•
 
Gross income. The IRS has pointed out in IR  
81-138 that although ERTA amended Sec. 274(b)
 to increase deduction limits for employer awards to
 employees, it didn’t change the determination of
 whether the awards are includible in the employee’s
 income. Whether an award is additional compensa
­tion or a gift depends on the facts in each case.
 Unless it can be shown that the award was made
 because of the employer’s detached generosity and
 in no way represented compensation for services
 rendered, the value of the award must be included
 in the employee’s income.
•
 
Partnerships. The IRS has announced that  
partnerships no longer have to complete Schedules
 L (Balance Sheets) and M (Reconciliation of Part
­ners’ Capital Accounts) of Form 1065 if certain tests
 are met. (IR 81-146.) A partnership won’t be re
­quired to complete Schedules L and M for 1981 and
 later if all of the following requirements are met: (1)
The partnership’s only income-producing activity is
 
from one or more of a family farm partnership, a
 family-owned wholesale or retail store partnership,
 or a co-ownership of investment property; (2) there
 are no more than 10 partners; (3) the partnership is
 a domestic partnership composed entirely of non
­corporate general partners; (4) the partnership isn’t
 in partnership with another partnership; (5) each
 partner’s interest in the capital is equal to his in
­terest in the profits; (6) all of the income, deductions,
 and credits are allocated to each partner in propor
­tion to the partner’s pro rata interest; and (7) Sched
­ules K-1 (Partner’s Share of Income, etc.) are 
filed with the return and furnished to the partners on or
 before the due date of the partnership return, includ
­ing extensions.
•
 
Change in IRS structure. In a recent speech,  
IRS Commissioner Roscoe L. Egger, Jr., discussed
 changes in the IRS’s organizational structure.
 Some of the highlights follow. Instead of many as
­sistant commissioners reporting directly to the
 Deputy Commissioner, three new executive posi
­tions have been created: Associate Commissioners
 for Operations, Policy and Management, and Data
 Processing. These executives will coordinate 
the activities of 
the
 assistant commissioners responsi ­
ble for functional direction of operating programs
 and will work on continuing policy development,
 oversight, and control of IRS activities. In addition,
 several new assistant commissioner positions 
have been created. In another change, the Appeals Divi
­sion has been transferred to the IRS Chief Counsel
 organization, together with the Individual Tax and
THE TAX ADVISER, MARCH 1982 171
1
Manning: thumbtax
Published by eGrove, 1982
Corporation Tax Divisions, which are involved in the
 
issuance of rulings. The Office of Chief Counsel
 also has been reorganized accordingly. Finally, the
 IRS has established the position of Assistant to the
 Commissioner for Congressional Affairs to consoli
­date all of the congressional liaison functions that
 
are
 currently decentralized throughout the IRS Na ­
tional Office.
•
 
Tax procedure. New Rev. Proc. 82-7 states  
the IRS’s requirements regarding the reproduction,
 private design, and printing of substitute Form
 1040-ES, Declaration of Estimated Tax for Individ
­uals, in lieu of the official form. In addition, the
 procedure states the requirements regarding the
 acceptance of computer-prepared and computer
­generated Forms 1040-ES.
•
 
Estate tax. New Rev. Proc. 82-9 provides  
guidelines for filing elections for special use valua
­tion under 
Sec.
 2032A, reinstatements of elections,  
and claims for credit or refund when estates qualify
 for special use valuation under the retroactive pro
­visions of ERTA.
•
 
Form reproduction. Recently issued Rev.  
Proc. 82-5 sets forth the requirements for reproduc
­ing paper substitutes for forms in the 1099 and 1087
 series. Rev. Proc. 82-5 supersedes Rev. Proc.
 79-17.
Regulations
•
 
Business expenses. The IRS has issued  
temporary regulations (T.D. 7802) under 
Sec.
 274  
relating to deductions for members of Congress for
 travel expenses in Washington, D.C., allowed with
­out substantiation. The 
regs.,
 which reflect the elim ­
ination of the former $3,000 limitation, provide that
 members of Congress may deduct a designated
 amount for each congressional day in the year. The
 designated amount (currently $75 
a
 day) is deter ­
mined by reference to the maximum amount of
 reimbursement available to a government employ
­ee traveling in Washington. Congressional days 
are determined by reducing the number of days in the
 year by periods in which Congress is not in session
 for five or more consecutive days. Two other op
­tions are also available. (Legislation has been intro
­duced that would limit or rescind the deduction.
 See, e.g., S. 2012 and S. 2015.)
•
 
Withholding rules. The IRS has issued final  
regulations (T.D. 7803) relating to the submission of
 certain withholding exemption certificates (Forms
 W-4). T.D. 7803 amends the proposed regs, and
 replaces the temporary regs. that were issued in
 March of last year. (See TTA, May 81, p. 304.)
Among other changes, the final regs. have been
 
modified to require the employers to submit to the
 IRS copies of Forms W-4 that claim more than 14
 exemptions, rather than more than nine exemp
­tions. The new rules are effective with respect to
 Forms W-4 furnished by employees to employers
 on or after Feb. 25, 1982.
•
 
Moving expenses. The IRS has issued final 
regulations (T.D. 7810) under Sec. 217 relating to
 special rules for foreign moving expenses and the
 allowance of moving expense deductions in the
 case of retirees or dependents of decedents who
 were working abroad. The regs. reflect changes
 made by the 78 Foreign Earned Income Act.
Forms
•
 
Research credit. Section 221 of ERTA pro ­
vides for 
a
 tax credit for increasing the research  
activities of a trade or business for tax years ending
 after June 30, 1981. New Form 6765, now avail
­able, is to be used to compute the credit. (Ann.
 82-3.)
People
•
 
Associate Commissioner. Joseph Davis has  
been appointed Associate Commissioner for Policy
 and Management. This new position was 
created as part of the recent IRS reorganization (see the
 related item on p. 171).
•
 
Chief Counsel’s aides. B. John Williams, Jr.,  
has been named special assistant to the IRS Chief
 Counsel. Also, Benjamin Sanchez has been ap
­pointed director of the general litigation division of
 the Chief Counsel’s office. Mr. Sanchez succeeds
 James Keightley, who was appointed Deputy Chief
 Counsel (General).
•
 
New district director. Arturo A. Jacobs has  
been appointed district director of the new IRS
 Houston district. Mr. Jacobs previously had been
 director of the Seattle district.
Miscellaneous
•
 
Court fees. Section 751 of ERTA authorized  
the Tax Court to increase from $10 to $60 the fee for
 filing a petition with the 
Court.
 The Court has an ­
nounced that the new fee is applicable to regular
 cases commenced after Feb. 28, 1982. The 
in­creased fee isn’t applicable when the taxpayer
 elects the special procedures applicable to small
 tax cases under Sec. 7463. The filing fee for those
 cases remains at $10.03
172 THE TAX ADVISER, MARCH 1982
2
Tax Adviser, Vol. 13 [1982], Iss. 3, Art. 6
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thumbtax

An important question in discrete topology and geometry is how to recover the structure and characteristics of a manifold when only given a finite set of points sampled from that manifold. Thus, if mathematicians have a point cloud of data which induces a discrete metric space, they look for some structure to these points. Understanding the structure of these points often gives needed insight to solve this problem. One such way to determine structure to these points is to use these points to construct a Vietoris-Rips complex. In abstract, Latschev shows that this allows us to recover the homotopy type of the manifold for a sufficiently small radius parameter. Adamaszek and Adams determined an explicit bound for the radius parameter in the case of circles. This thesis develops a different proof strategy using Discrete Morse theory on simplicial complexes coming from two types of discrete approximations of the circle. We prove that when constructing a Vietoris-Rips complex, if we choose a radius smaller than a third of the entire circumference of the circle, then the complex is simple homotopy equivalent to the circle itself

Mobley, Alexander J

Exploration into Homotopy Equivalence and Vietoris-Rips Complexes

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Allen, Heather

Marting, Diane

09. Presentación de grupo

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Contra la gastronomía peruana

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La Educación Sexual Integral (ESI) en la Argentina

Heironimus, M. Eddie

IRS viewpoint: CPA participation in Volunteer Income Tax Assistance (VITA) and Student Tax Clinics

Bereson, David A.

Blank, Jacob M.

Bankruptcy Tax Act of 1980 (part I)

Rabin, Alan

Richard, W. Mason

Tax Adviser 
Volume 12 Issue 6 Article 3 
1981 
Still more on income averaging 
Alan Rabin 
W. Mason Richard 
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 Part of the Accounting Commons, and the Taxation Commons 
Recommended Citation 
Rabin, Alan and Richard, W. Mason (1981) "Still more on income averaging," Tax Adviser: Vol. 12: Iss. 6, 
Article 3. 
Available at: https://egrove.olemiss.edu/tax_adviser/vol12/iss6/3 
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ALAN RABIN, Ph.D.,
 
assistant professor of economics,
 School of Business Administration,
 The University of Tennessee,
 Chattanooga, Tenn.
W. MASON RICHARD. MBA, CPA,
 
associate professor of accounting,
 Dalton 
Junior
 College,  
Dalton, Ga.
Still more on income averaging
In reply to comments by Robert M. Ross, Jr., in a
 
1979 article on income averaging, Jonathan J.
 
Davies
 and Sam A. Hicks assert: “The current  
averaging system, by relying on five separate calcu
­lations, denies the taxpayer the right to use 
excess deductions of one 
base
 year as an offset against  
excess income of another.”1 We shall show that this
 no longer holds true in all cases. Moreover, in their
 
origi
nal article Davies and Hicks state: “The funda ­
mental defect of the 1977 averaging system man
­ifests itself in the form of increased taxes in almost
 any situation where taxable income during 
the
 base  
period was lower than the current zero bracket
 amount.”2
1
 
Reply by Davies and Hicks to  article  by Ross, "More on income  
averaging,” 148 J. of Accountancy 96 (Dec. 1979), at p. 97.
2
 
Davies  and Hicks, "Income averaging: a practical evaluation of  
the cost of simplification,” 147 J. of Accountancy 88 (Jan.
 1979), at p. 91. This statement seems to imply that only those
 taxpayers with adjusted gross income lower than the zero
 bracket amount during the base period
 
would pay higher taxes  
under the 1977 method than under the 1976 method. This is
 partially true, for all taxpayers who income average would pay a
 higher tax in 1977 under the 1977 method, since the calculation
 system inflates nonaveragable income by 20% of the zero
 bracket amount.
348 THE TAX ADVISER, JUNE 1981
1
Rabin and Richard: Still more on income averaging
Published by eGrove, 1981
We 
shall
 demonstrate that although taxpayers  
who averaged their income will have paid 
a
 higher  
tax in 1977 under the 1977 method than under the
 1976 method, beginning in 1978, taxpayers with
 base period adjusted gross income less than the
 zero bracket amount 
will
 actually pay a lower tax  
than taxpayers in similar situations in 1977. The
 reason is that the pre-1977 method 
did
 not allow the  
taxpayer to reduce nonaveragable income in the
 computational year by unused standard deductions
 in base 
years.
 However, beginning in 1978 and  
continuing thereafter, a person with adjusted gross
 income less than the zero bracket amount (in base
 period years 1977 and after) may use the difference
 to decrease nonaveragable income (and therefore
 increase averagable income) in the computational
 year, resulting in a lower tax. The reason for this
 phenomenon is that, beginning in 1977, the tax
 schedule has 
a
 built-in zero bracket amount of  
$2,200 for the taxpayer who is single.3 Hence, start
­ing in computational year 1977, $2,200 
is
 added to  
adjusted gross income in computing base period
 income for 
base
 period years prior to 1977. For  
base period years 1977 and after, this adjustment is  
not added in. Consequently, 
if
 adjusted gross in ­
come is less than $2,200 for 
a
 base period year  
(1977 and after), then base period income 
will
 in fact  
be below $2,200 for that year.4 The difference be
­tween the zero bracket amount and adjusted gross
 income is used to reduce nonaveragable income in
 the computational year.5 For example, in 1977, a
 person’s base period income for prior years would
 be $2,200 each year, assuming adjusted gross in
­come of $0 in each of those years. However, in
 1978, the base period income for 1977 would be $0
 given that adjusted gross income was $0 for 1977.
 The net effect would be, therefore, to reduce non
­averagable income in computational year 1978.
 Once adjusted gross income equals or exceeds the
 zero bracket amount, no such reduction takes
 
place
. Thus, if adjusted gross income were $2,300  
in each of the base period years and were $11,000
 in the computational year, then the tax liability would
 be identical for the computational years 1977,1978,
 1979, 1980, etc. (The above assumes standard
3
 
Beginning in 1979, the zero bracket amount is $2,300. How ­
ever,
 
only $2,200 is added to base period year income for 1975  
and 1976.
4
 
In this note we ignore the effect of exemptions and income  
earned outside of the U.S. Thus, base period income for 1977
 and 
after
 is simply adjusted gross income.
5
 
For every dollar below the zero bracket amount in a base period  
year, nonaveragable income is decreased by $.30 in the com
­putational year.
6
 
The case presented is not so extreme for  those graduate stu­
dents at college who are self-supporting (through higher educa
­tion loans).
7
 
The tax begins to decrease in 1978, for beginning in 1978 base  
period income (for 1977) may be reported as zero given 
ad­justed gross income is zero. However, in computational year
 1977, 
the
 minimum income for each of the base period years is  
$2,200, since that 
amount
 must be added in!
deductions equal to the zero bracket amount. It
 
also, of course, disregards changes in the zero
 bracket amount or changes 
in
 tax rates.) It is in ­
teresting to note that the effect mentioned by Davies
 and Hicks 
will
 still occur in the future even though  
the steps for income averaging 
will
 have changed  
somewhat. In other words, although the zero brack
­et amount is not explicitly added to base period
 income in 1977 and after, this amount is implicitly
 included, since base period income is now defined
 as adjusted gross income in our examples.
Illustrations
We have illustrated the situations for six years:
 
1976, 1977, 1978, 1979, 1980, and 1981. In each
 case we assume a single taxpayer with $11,000
 income in the computational year and $0 adjusted
 gross income in each of the base period years. In
 each case we ignore the effect of exemptions and
 apply the tax rates of 1978. These assumptions
 allow us to illustrate the major differences among
 the six years.6 As can be seen, the tax liability is
 $1,346.00 
i
 1976, $1,410.00 in 1977, $1,196.40 in  
1978, $769.80 in 1979, $371.00 in 1980, and $0 in
 1981. This demonstrates that six individuals with
 identical incomes, but in different years, 
will
 pay six  
different taxes, with the tax burden decreasing each
 year. The tax liability increases between 1976 and
 1977 for the reasons given in the article by Davies
 and Hicks.7
Conclusion
The zero bracket amount is being phased in over
 
the period 1978-1981. During this transition period,
 taxpayers with base period adjusted gross income
 less than the zero bracket amount are treated dif
­ferently in each of the years 1977 through 1981.
 Beginning in 1981, these taxpayers will reap the
 maximum benefits in that they will be able to use
 fully base period unused zero bracket amounts to
 decrease nonaveragable income in the computa
­tional year. Of course, the Davies-Hicks effect will
 still be present in those cases where base period
 income is greater than zero.
[See illustrations on the following page.]
THE TAX ADVISER, JUNE 1981 349 2
Tax Adviser, Vol. 12 [1981], Iss. 6, Art. 3
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Taxpayer #1, 1976*
1976 1975 1974 1973 1972
Adjusted 
gross
 income $11,000 $0 $0 $0 $0
Base period income — 0 0 0 0
Averagable income 8,800 — — — —
Nonaveragable income 0 — — — —
Tax liability 1,346 — — — —
* In each situation we ignored 
the
 effect of  exemptions. The inclusion of such figures would not alter the  
comparisons. We applied the tax rates of 1978 in each situation. The tax credit was also ignored.
 
In 1976  
we assumed a standard deduction equal to the zero bracket amount. Hence, averagable income is
 $8,800 in 1976.
Taxpayer #2, 1977
1977 1976 1975 1974 1973
Adjusted gross income $11,000 $0 $0 $0 $0
Adjustment — 2,200 2,200 2,200 2,200
Base period income — 2,200 2,200 2,200 2,200
Averagable income 8,360 — — — —
Nonaveragable income 2,640 — — — —
Tax liability 1,410 — — — —
Taxpayer #3, 1978
1978 1977 1976 1975 1974
Adjusted gross income $11,000 $0 $0 $0 $0
Adjustment — — 2,200 2,200 2,200
Base period income — 0 2,200 2,200 2,200
Averagable income 9,020 — — — —
Nonaveragable income 1,980 — — — —
Tax liability 1,196.40 — — — —
Taxpayer #4,1979
1979 1978 1977 1976 1975
Adjusted gross income $11,000 $0 $0 $0
$0
Adjustment — — — 2,200 2,200
Base period income — 0 0 2,200 2,200
Averagable
 income 9,680 — — — —
Nonaveragable income 1,320 — — — —
Tax liability 769.80 — — — —
Taxpayer #5,1980
1980 1979 1978 1977 1976
Adjusted gross income $11,000 $0
$0
$0 $0
Adjustment — — — — 2,200
Base period income — 0 0 0 2,200
Averagable income 10,340 — — — —
Nonaveragable income 660 — — — —
Tax liability 371 — — — —
Taxpayer #6,1981
1981 1980 1979 1978 1977
Adjusted gross income $11,000 $0 $0 $0 $0
Adjustment — — — — —
Base period income — 0 0 0 0
Averagable income 11,000 — — — —
Nonaveragable income 0 — — — —
Tax liability 0 — — — —
350 THE TAX ADVISER, JUNE 1981
3
Rabin and Richard: Still more on income averaging
Published by eGrove, 1981


Still more on income averaging

Linett, E. S.

tax trends

American Institute of Certified Public Accountants

Tax Adviser 
Volume 12 Issue 6 Article 9 
1981 
Author index, 12 months ended May 1981 
American Institute of Certified Public Accountants 
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Adviser: Vol. 12: Iss. 6, Article 9. 
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author index
12 months ended
 
May 1981
Abbin, Byrle M.
Significant recent developments concerning estate planning
 
—1981. Part 1—81:202. Part 11—81:266.
Adler, Michael
The allocation of interest and R&D under Regs. Sec. 1.861-
 
8(e): questions from the entrails. 80:597.
Adney, John T.
Life insurance companies and the income tax: recent judicial
 
developments. 80:388.
Berenson, David A.
The Bankruptcy Tax Act of 1980. Part I—81:68. Part II—
 
81:147. Part 111—81:277.
Bishop, David G.
Recapture of excess housing deductions under 
the
 Technical  
Corrections Act of 1979. 80:411.
Blank, Jacob M.
The Bankruptcy Tax Act of 1980. Part I—81:68. Part II—
 
81:147.
Boyd, James H.
Simplified employee pensions: 
the
 new-style IRA. 80:532.
Bush, Julian S.
Planning and tax considerations in the use of revocable trusts.
 
Part 1—80:654. Part 11—80:717. Part 111—81:14. Part IV—
 81:79.
Capron, Jeffery P.
Rev. Proc. 80-51 and the new IRS rules for changes in ac
­
counting methods. 81:132.
Carlson, David K.
Significant recent developments concerning estate
 
planning—1981. Part 1—81:202. Part 11—81:266.
Chapman, Benson J.
Sec. 83: new developments in executive compensation.
 
81:89.
Cheeks, James E.
The new tax cost of excessive compensation. 81:196.
Chiechi, Carolyn P.
Life insurance companies and 
the
 income tax: recent judicial  
developments. 80:388.
Colleran, Michael C.
An analysis of the Installment Sales Revision Act of 1980.
 
81:4.
Crooks, Barbara
Simplified employee pensions: the new-style IRA. 80:532.
Davenport, Lou B.
Accounting for vacation pay: is it time to change your method?
 
80:676.
Davies, Jonathan J.
The IRS approach to the wrap-around mortgage: a contradic
­
tion of tax fundamentals. 81:260.
Davison, Dale L.
Valuation methods in exchanges of stock for assets. 80:396.
Dickman, Marvin J.
A business approach to subchap. S. 80:463.
Diss, William T.
Tax contingency audit workpapers: current developments,
 
observations, and proposals. 81:104.
Dye, Alan P.
Grassroots lobbying and the new proposed regulations.
 
81:214.
Feinschreiber, Robert
The
 unitary method of state taxation after Mobil and Exxon.  
80:708.
Goggans, Travis P.
Gifts to minors—alternative methods and their tax effects.
 
80:592.
Grattan, John B.
Repeal of carryover basis
 
revives estate planning techniques.  
80:402.
Hanson, Robert E.
Tax contingency audit workpapers: 
current
 developments,  
observations, and proposals. 81:104.
Heironimus, M. Eddie
CPA participation in Volunteer Income Tax Assistance (VITA)
 
and Student Tax Clinics. 81:38.
Heller, Kenneth H.
Working with the at-risk rules: a practical approach. 80:644.
Honecker, Ernest
The Bankruptcy Tax Act of 1980 (part III). 81:277.
Horvitz, 
Jerome
 S.
An examination of the IRS’s voluntary disclosure policy.
 80:545.
Jensen, Herbert L.
Willfulness and the 100% penalty. 80:664.
Jewett, Susan
The proposed regulations under Sec. 385. 80:324.
Johnson, Janice M.
The IRS’s 
war
 on abusive tax shelters. 80:358. Technical  
advice from 
Assistant
 Commissioner Portney. 80:746. Tax  
Division comments: proposed regs, on tax shelter opinions.
 81:42. AICPA suggestions for improvement of Social Security
 system. 81:300.
Kasischke, Louis W.
New procedures to obtain an IRS ruling. 80:580.
Kruger, Daniel F.
Sec. 83: new developments in executive compensation.
 
81:89.
Lamaute, Denise
The
 taxation of group-term life insurance: Sec. 79. 81:21.
THE TAX ADVISER, JUNE 1981 383 1
: Author index, 12 months ended May 1981
Published by eGrove, 1981
Linett, Eugene S.
For Tax Trends column, 
see
 “at a glance” page of each issue.
Mancino, Douglas M.
Lobbying by 
public
 charities. 80:452.
Manning, Robert F.
For the Thumbtax column, see “at a glance” page of each
 
issue.
Mansfield, Edward
The IRS approach to 
the
 wrap-around mortgage: a contradic ­
tion of 
tax
 fundamentals. 81:260.
Maples, Lawrence
Storage facilities and 
the
 investment credit. 80:724.
McCormally, Timothy J.
The
 common paymaster rules of Secs. 3121(s) and 3306(p):  
an analysis of the final regs. 80:516.
Nackenson, Caryl
The unitary method of state taxation after Mobil and Exxon.
 
80:708.
Nygaard, Terry R.
Accounting for vacation pay: is it time to change 
your
 method?  
80:676.
Pehrson, Gordon O., Jr.
Life insurance companies and the income tax: recent judicial
 
developments. 80:388.
Porcano, Thomas M.
Planning for the transfer of a personal residence. 80:522.
Prescott, M. Keith
Like-kind exchanges of partnership interests. 80:739.
Reeder, Janis R.
Valuation methods in exchanges of stock for assets. 80:396.
Robbins, Valerie C.
Sale and leaseback of real property after Frank Lyon Co.
 
80:476.
Rosenthal, Jeffery R.
An analysis of the Installment Sales Revision Act of 1980.
 
81:4.
Schnee, Edward J.
Stock redemptions from estates and trusts—continued confu
­
sion. 80:348.
Smith, James E.
Partnership at-risk rules after the '78 Revenue Act. 80:330.
Streer, Paul J.
Working with the at-risk rules: a practical approach. 80:644.
Strobel,
 Caroline D.
Tax advantages of partial gifts to charity. 81:140.
Stromsem, William R.
Kurtz discusses preparer penalties with Tax Division. 80:425.
AICPA Tax Recommendations to Aid Small Business. 80:551.
IRS adopts guidelines for preparer negligence penalty.
 
80:684. Recent LIFO developments. 81:173. Meeting with
 IRS: Compliance and Taxpayer
 
Service and Returns Proces ­
sing issues. 81:232.
Tallichet, Henri L.
An examination of 
the
 IRS’s voluntary disclosure policy.  
80:545.
Thomas, Kenneth F.
The IRS’s war on abusive tax shelters. 80:358. Kurtz discus
­
ses preparer 
penalties
 with Tax Division. 80:425. Statement of  
tax policy on capital 
cost
 recovery. 80:485. AICPA Tax Re ­
commendations to Aid Small Business. 80:551. New legisla
­tive proposals on capital cost recovery. 80:617. IRS adopts
 guidelines for preparer negligence
 
penalty. 80:684. Technical  
advice from Assistant Commissioner Portney. 80:746. Tax
 Division comments: proposed regs, on tax shelter opinions.
 81:42. Recent LIFO developments. 81:173. Meeting with IRS:
 Compliance and 
Taxpayer
 Service and Returns Processing  
issues. 81:232. AICPA suggestions for improvement of Social
 Security system. 81:300.
Webster, George D.
Grassroots lobbying and the new proposed regulations.
 
81:214.
Wolff, Laroy W., Jr.
LIFO layer valuations under the dollar-value index method.
 
81:161.
Zaritsky, Howard M.
Planning and tax considerations in the use of revocable trusts.
 
Part 1—80:654. Part 11—80:717. Part 111—81:14. Part IV—
 81:79.
Zimmermann, Peter F.
Statement of 
tax
 policy  on capital cost recovery. 80:485. New  
legislative proposals on capital cost recovery. 80:617.
Zumpano, Leonard
The IRS approach to the wrap-around mortgage: a contradic
­
tion of 
tax
 fundamentals. 81:260.
Tax clinic editors
Broenen, Darwin Lerner, Herbert J.
Nov. 80:668. Aug. 80:468.
Diss, William T. O’Connell, Frank J., Jr.
Jan. 81:28. Sept. 80:538.
Elder, Peter Padwe, Gerald W.
Apr. 81:222. Mar. 81:152.
Ellentuck, Albert B. Power, James E.
Oct. 80:609. Dec. 80:730.
Hennessey, Kevin Tarantino, Dominic A.
June 80:338. July 80:414.
Josephs, Stuart R. Vollman, Stanton H.
May 81:286. Feb. 81:94.
Key to page references
Pages Issue Pages issue Pages Issue
80:321-384 June 80 80:577-640 Oct. 
80
81:65-128 Feb. 81
80:385-448 July 80 80:641-704 Nov. 80 81:129-192 March 81
80:449-512 Aug. 80 80:705-768 Dec. 80 81:193-256 April 81
80:513-576 Sept. 80 81:1-64 Jan. 81 81:257-320 May 81
384 THE 
TAX
 ADVISER, JUNE 1981
2
Tax Adviser, Vol. 12 [1981], Iss. 6, Art. 9
https://egrove.olemiss.edu/tax_adviser/vol12/iss6/9


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