Term/Phrase Page

1014 (stepped-up basis, applies to transfer by bequest) 27, 59

1015 (carryover basis, applies to transfers by gift) 26
102 (gifts) 25
103 (excludes interest on debt obligations of states) 25
1031 (like-kind exchanges) 65-66
104 (damages in general) 23
1041 (gain/loss not recognized incident to spousal trans.) 58
108 (exclusions) 21
1221 (capital asset) 59
1222 (capital gains/losses) 59
1231 (quasi-capital gains & losses) 62
1239 (sale of depreciable property to related party) 64
1245 (recapture depreciation of personal property) 63
1250 (recapture depreciation of real property) 64
151 (personal exemption) 33
152 (dependency exemption) 33
162 (trade or business expenses) 43
164 (deductibility of state, local & foreign taxes) 32
167 (depreciation) 17, 38
170 (charitable contributions) 30
212 (expenses for production of income) 43
262 (personal, living & family expenses) 44
263 (capital expenditures) 44
71 (alimony) 35
72 (annuity exclusion) 19
7702 (see investment of life insurance) 28
83 (property transferred for services rendered) 9
30-day letter 2
401(K) 14
84-176, Revenue Ruling 22
90-day letter (deficiency notice) 2
99-7, Revenue Ruling (daily transportation expenses) 48
accelerated death benefits (of life insurance) 29
accessions to wealth 5
accounting methods 13
accrual-method 13
achievement award (see employee achievement award) 27
adjusted basis 7
adjusted gross income 2
alimony 35
alimony, basic requirements for taxable/deductible 35
allocation of basis 55
amount realized 6
annuities 19
annuity payment for damages (structured settlement) 24
appreciated property, contributions of 32
appreciation 6
automatic dividend rule 47
awards (see prizes) 27
away from home: for deducting meals & travel 49
bargain purchases 7
basic tax computations 2
basis (see specifics below) 7
basis, & depreciation 38
1
basis, adjusted 7
basis, allocation 55
basis, bequests 27, 59
basis, carryover (general rule of gifts) 26
basis, gifts 26, 58
basis, of property acquired by exercising option 55
basis, stepped-up (general rule of bequests) 27, 59
bequests, basis of 27
bequests, gifts 26
bequests, stepped-up basis 27, 59
Blair v. Commissioner 53
bonds & coupons on bonds, who is taxpayer 53
bonuses to employees 47
boot, received in an exchange 65
borrowing, general notes on 20
business & investment expenses 38
business vs. personal origination of lawsuit 45
buy-sell agreements 29
cancellation of indebtedness 20
cancellation of indebtedness: reduction of basis following 21
capital assets 59
capital assets, items that are not 62
capital expenditures 40
capital expenditures 44
capital expenditures vs. deductible repairs 40
capital gains & charitable contribution deduction 65
capital gains & losses 59
capital gains, policy considerations in taxation of 61
capital investments vs. ordinary & necessary expenses 18
capital losses 61
capital, recovery of 17
carrying charges, form of interest 50
carrying-on requirement 49
carryover basis (general rule of gifts) 26
cash value (of whole life insurance) 28
cash-method 13
casualty fire pot ( 1231) 63
Cesarini v. U.S. 5
charitable contributions & capital gains 65
charitable contributions & tax-exempt organizations 30
charitable transfer (exception to prizes) 27
charitable transfer (general rules of) 30
child support, not alimony 35
child tax credits 3
children, taxation of income of minors 53
clothing, deductible for trade or business 46
commuting expenses 47
commuting, daily transportation expenses 48
compensation for services rendered 8
compensation for services rendered (property) 9
computations, basic tax 2
computations, realized gain or loss 55
consideration vs. gift 58
constructive receipt 15
contributions of appreciated property 32
2
copyright, not capital asset 59, 62
cost recovery, depreciation 38
court, choice of 2
Crane v. Commissioner 40, 56
credits, child 3
credits, personal 36
custodial parents (dependency exemption) 33
damages, in general 23
damages, other than punitives, not included in gross income 24
damages, taxation of 23
Davis v. U.S. (overturned by 1041) 58
death benefits, accelerated (of life insurance) 29
debt, cancellation of 20
declining-balance method (depreciation) 38
deductions, itemized 3
deductions, standard 3
deferred compensation 13
deferred compensation (qualified) arrangements 10, 14
deferred compensation, non-qualified, contractual 15
deficiency notice (90-day letter) 2
dependency exemption 33
dependent-care services, tax credit 36
depreciation 17
depreciation & basis 38
depreciation of intangible property 39
depreciation vs. expensing 39
depreciation, business & investment expenses 38
depreciation, of improvements 39
depreciation, of like-kind exchanges 66
discharge of indebtedness 20
discounts, employee 7
dividend vs. salary 46
dividend, stock: distribution not taxable event 5
dividends, taxable w/o regard to cost basis 17
division of property, not alimony 35
divorce, economics of 35
divorce/marriage transfers 58
divorced parents (dependency exemption) 33
donor's intent (gifts, Duberstein ) 25
Duberstein v. Commissioner 25
earned-income credit 36
Eisner v. Macomber 5, 54
Elliotts, Inc. v. Commissioner 47
embezzled funds, as income to embezzler 15
employee achievement award (exception to prizes) 27
employee discounts 7
employees, gifts to 26
employment-related expenses, personal tax credit 36
exchanges, like-kind 65
exclusion ratio (of an annuity) 19
exemption, dependency 33
exemption, personal 33
expected return (of an annuity) 19
expenses, capitalized 42
expensing in lieu of depreciation 39
3
family partnership 53
Farid-Es-Sultaneh v. Commissioner 58
filing status 34
filing status & personal exemptions 33
Fire pot ( 1231) 63
FMV or basis, which to use in gifting property 58
foreign, local & state taxes 32
forfeiture, substantial risk of 10
forum, choice of 2
gain 6
gain, illegal 15
gift vs. contractual consideration 58
gifts 25, 58
gifts, basis of 26, 58
gifts, bequests/inheritances 26, 59
gifts, of income from property 26
gifts, to employees 26
Gilmore v. U.S. 45
Glenshaw Glass Co. 5
gross income 1, 5
gross income from sales 6
gross income restriction (dependency exemption) 34
group term insurance 28
Hampton Pontiac v. U.S. 18
Hantzis v. Commissioner 49
Harris v. U.S. 25
Haverly v. U.S. 32
head of household, filing status 34
Helvering v. Horst 53
Helvering v. Welch 46
Hirsch v. Commissioner 22
Horst v. Helvering 53
household & dependent care services, tax credit 36
Idaho Power v. Commissioner 41
illegal gain 15
improvements, depreciation of 39
imputed income 24
imputed interest 50
in lieu of (test for taxation of damages) 23
Inaja v. Commissioner 56
incentive stock options 11
income from dealings in property 54
income from property, as gifts 26
income from property, who is taxpayer 53
income, adjusted gross 2
income, gross 1, 5
income, of minor children, taxation of 53
income, taxable 1, 2
indebtedness, qualified real property business 22
INDOPCO v. Commissioner 42
inheritances, gifts 26
injuries, damages for business & personal 24
injuries, damages for personal injuries 24
insolvency exception to cancellation of indebtedness 21
insolvency, definition 21
4
insurance, group term 28
insurance, life 27
insurance, term 28
insurance, whole life 28
intangible property, depreciation of 39
intent of donor (gifts, Duberstein ) 25
interest income & deductions 50
interest, forms of 50
interest, imputed 50
interest, personal 51
interest, state & local obligatons 25
interest, taxable w/o regard to cost basis 17
internal revenue service 1
International Freighting Corp., Inc. v. Commr. 54
inventories 43
inventory, not capital asset 59, 62
investment (of life insurance) 28
investment (of life insurance) taxation of 29
IRA contributions, tax credit for 14
IRA, Roth 13
IRA, traditional 14
itemized deductions 3
itemized deductions, reduction of 4
James v. U.S. 15
Kemon v. Commissioner 62
Kenseth v. Commissioner 44
key person insurance 29
Kirby Lumber Co. v. U.S. 20
letter rulings 1
liabilities giving rise to deductions 22
liability insurers, payments by 9
life insurance proceeds 27
life insurance trust 29
life insurance, taxation of (combine insure & invest) 29
life insurance, term insurance 28
life insurance, transfer for value 29
life insurance, whole 28
like-kind exchanges 65
like-kind exchanges, depreciation of 66
like-kind property 66
limitations, statute of 2
loan-forgiveness programs 23
LoBue v. Commissioner 9
local & state obligations, interest on 25
local, state & foreign taxes 32
long-term/short-term, capital 60
loss 6
lost payments vs. discharge of indebtedness 22
lower of basis or FMV rule 58
Lucas v. Earl 52
lunches, daily: not deductible 48
Macomber 5, 54
marriage/divorce transfers 58
Midland v. Empire 41
minor children, taxation of their income 53
5
mortality gain (annuities) 20
mortality loss (annuities) 20
mortgaged property, transfers involving 56
Moss v. Commissioner 48
moving expenses, carrying-on requirement 50
Mt. Morris Drive-in Theatre Co. 41
multiple support agreements (dependency exemption) 34
Nahey v. Commissioner 61
net-operating carryover 21
non-qualified stock options 10, 11
non-qualified, contractual (deferred compensation) 15
non-recognition transaction & disallowance of losses 65
obligation of payor 9
Old Colony Trust Co. v. Commissioner 8
opportunity cost 12
option, basis of property acquired by exercising 55
ordinary & necessary 46
organizational expenditures, depreciation 40
origination of expenses (business vs. personal) 45
paintings, as capital asset 59
Parker v. Delaney 56
payor, obligation of 9
personal exemption 33
personal exemptions 2
personal exemptions & filing status 33
personal exemptions phase-outs 4
personal injuries, damages for 24
personal interest 51
personal service income, who is taxpayer 52
personal tax credits 36
personal, living & family expenses 44
Pevsner v. Commissioner 45-46
phase-outs, personal exemptions 4
Plainfield-Union test 40
Plainfield-Union v. Commissioner 40
Poe v. Seaborn 52
points, form of interest 50
prizes 27
prizes, exceptions to 27
production of income, expenses for 43
progressive rate system 1
property acquired by bequest, basis of 59
property acquired by gift, basis of 58
property acquired by inheritance, basis of 59
property as compensation for services rendered 9
property as compensation, income & basis 12
property, analysis of transaction 54
property, basis of that acquired by exercising option 55
property, contributions of appreciated 32
property, income from dealings in 54
property, income from, who is taxpayer 53
property, like-kind 66
property, sale of depreciable to related party 64
property, transfers involving mortgaged 56
proportional rate system 1
6
purchase price, reduction of (cancellation of indebtedness) 22
QDRO (qualified domestic relations order) 15, 36
qualified (deferred compensation) arrangments 10, 14
qualified domestic relations order (QDRO) 15, 36
qualified real property business indebtedness 22
Rail Joint v. Commissioner 22
rail-joint principle 22
rate systems 1
Raytheon Production Corp. v. Commissioner 23
realization 5, 7
realization, computation of gain or loss 55
realization, has sale/exchange occurred? 54
reasonableness of compensation to employee 47
recapture of depreciation 63
recognition 7
recovery of capital 17
reduction of basis following cancellation of indebtedness 21
reduction of itemized deductions 4
reduction of purchase price (cancellation of indebtedness) 22
Regenstein v. Edwards 41
regressive rate system 1
rehabilitation, general plan of 41
related party, sale of depreciable property to 64
rent, taxable w/o regard to cost basis 17
repairs, deductible vs. capital expenditures 40
Revenue Ruling 84-176 22
Revenue Ruling 90-16 56
Revenue Ruling 99-7 (daily transportation expenses) 48
Robertson v. Commissioner 49
roll-overs, tax-free 14, 66
Roth IRA 13
rulings, letter 1
Sager Glove Corp. v. Commissioner 23
salary vs. dividend 46
salary, as trade or business expense 46
salary, reasonableness 47
sale of depreciable property to related party 64
sale-or-exchange requirement (capital gains) 61
securities, held for sale to customers in business 62
seeking employment, costs of, carrying-on requirement 50
services rendered, compensation for 8
services rendered, compensation for (property) 9
spouse-to-spouse (or former spouse) transfers 58
standard deductions 3
start-up & expansion costs, carrying-on requirement 50
state & local obligations, interest on 25
state, local & foreign taxes 32
statute of limitations 2
stepped-up basis (general rule of bequests) 27, 59
stock dividend: distribution not taxable event 5
stock option plan: compensation for services 9
stock options, incentive 11
stock options, non-qualified 10
stocks, as capital asset 59
straight-line depreciation 17, 38
7
structured settlement (annuity payment for damages) 24
substantial risk of forfeiture 10
substantially vested (property) 10
substantiation requirements of contributions 31
Tank Truck Rentals 50
tax controversies 2
tax rate (tax rate system) 1
taxable income 1, 2
taxes, state, local & foreign 32
tax-exempt organizations 30
tax-free exchanges 65
taxpayer, who is 51
temporary business, away from home 49
term insurance 28
time-value of money 13
tracing, re: interest 51
trade or business expenses 43
traditional IRA 14
transfer for value (of life insurance policy) 29
transfers involving mortgaged property 56
travel & entertainment 47
treasure trove 5
Turner v. Commissioner 27
uniform, deductible 46
voluntary payment 8
wasting investment requirement 17
Welch v. Helvering 46
whole life insurance 28
Wilcox , overruled by James 16
Wild v. Commissioner 45
Williams v. Commissioner 24
windfall ($$ in piano example) 5
Woodsam v. Commissioner 56
worker's comp, not included in gross income 24
Yeager v. Commissioner 44
8