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Browse Sager, Clayton R. 1-15 out of 15 article(s) Title Type Date Words QTIP and non-QTIP asset aggregation for estate tax valuation purposes rejected. Jun 1, 1999 1260 TC denies sec. 83 property compensation deduction. Aug 1, 1998 1037 Purchase of QTIP remainder interest for FMV is a gift. Jun 1, 1998 1082 QTIP cannot escape taxation in both spouses' estates. May 1, 1998 1087 Sec. 1341(a) income tax benefit is includible in the gross estate. Oct 1, 1997 972 Ninth Circuit rejects SOL exception. Aug 1, 1997 709 Tax Court denies C corporation sec. 104(a)(2) personal injury exclusion. Oct 1, 1996 863 Eleventh Circuit directs Tax Court to develop test for substantial understatement penalty. May 1, 1996 1798 Ninth Circuit disallows Keogh deduction based on S income. Apr 1, 1996 961 Tax Court restricts S corporation shareholder's basis for loss deductions. May 1, 1995 1350 Tax Court specifies conditions for accepting settlement allocations. Sep 1, 1994 1360 District Court rules wife's refund applies to husband's past-due child support. Sep 1, 1993 568 Payment for suicide allegedly caused by job stress is excludible. Jun 1, 1993 823 Supreme Court decides back pay taxability. Mar 1, 1993 941 Tax rate changes in malpractice cases. May 1, 1992 617

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