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Split purchases; an underutilized tax saving technique.

Split Purchases

An Underutilized Tax Saving Technique

Because of the repeal of the General Utilities doctrine, double taxation normally results on the liquidation of a C corporation. As a result, it has become less attractive for a corporation to directly own properties it needs for business purposes. A frequently used alternative is for the corporation to lease property from its shareholders or from a third party. In addition, an underutilized technique, a split purchase by the corporation and its shareholders, should be considered in many cases. The proper use of a split purchase will avoid any and all tax on a corporate liquidation, transfer wealth to the shareholders without dividend distributions, shelter corporate income through the amortization of the term interest and reduce earning and profits!

Since the 1920s taxpayers acquiring by purchase a term interest, life estate or income interest in a trust have been able to amortize their bases in such interests, straight line, over the term or expected duration of the interest.(1) The amortization deduction has been allowed for a present interest in all kinds of property, whether depreciable or nondepreciable, income producing or not, such as raw land,(2) securities and even tax-exempt municipal bonds!(3)

Example: C, Inc., purchased a 10-year income interest, a term interest, in a trust funded with a parking lot for $60,000. The lot was worth $100,000. C, Inc. can amortize and deduct $6,000 per year for 10 years while collecting rental income on the full $100,000, thus sheltering the income in full or in part. After 10 years, C has no interest in the trust and has recovered its basis.

Although somewhat restricted by the Revenue Reconciliation Act of 1989, there are still opportunities available to expense the purchase price of term interests in property by corporations and their shareholders.

Split Purchases, Present and Future Interests

When two parties simultaneously purchase a present interest and a future interest in property respectively, adding up to full ownership between them, the transaction is generally known as a split purchase (sometimes referred to as a joint purchase). The holder of the future interest is known as the remainderman.

Example: C, Inc., and its shareholders A and B fund a trust with $100,000 to be invested in a parking lot. C, Inc., purchases a 10-year term interest for $60,000, and A and B purchase the remainder for $40,000 as tenants in common. All income is distributed and taxed to C, Inc., for 10 years, but it amortizes and deducts $6,000 of its basis each year as well. After 10 years the trust terminates and A and B are the sole owners of the land. C, Inc., has recovered its $60,000 basis and A and B's original basis of $40,000 is now their basis in the lot. A and B thus, most likely, have a built-in gain. However, the gain is deferred until sale or even permanently if A and B retain the property for life, since a tax-free step-up in basis results when testamentary transfers of property occur.(4)

The Revenue Reconciliation Act of 1989

Section 167(r), as added by the Revenue Reconciliation Act of 1989, reduces a corporation's ability to expense the purchase price of a term interest. In short, term interests acquired after July 27, 1989, must still be amortized, but if the holders of the present future interests are "related" in the tax sense under Section 267, the amortization deduction is disallowed and added to the remainderman's basis.(5)

Example 1 -- Unrelated Parties: C, Inc., and its shareholders A and B engage in a split purchase of land in trust with C, Inc., paying $60,000 for the term interest and A and B $40,000 for the remainder. If C, Inc., and the shareholders are "unrelated" for tax purposes, A deducts $6,000 a year for 10 years, recovering its basis, and A and B's $40,000 basis is frozen.

Example 2 -- Related Parties:

Same as Example 1 except A and B are parent and child. Section 167(r) applies with the result that C, Inc., must reduce its basis by $6,000 a year without receiving a deduction while A and B increase their basis by $6,000 a year. After 10 years A and B own the land with a basis of $100,000, the original purchase price.

Thus, the increase in the remaindermen's basis is a substitute for the disallowance of the present interest holder's amortization deduction. At the expiration of the present interest, the remaindermen are put in the same position as if they had originally purchased the property. In the example above, A and B paid $40,000 to receive land with a basis of $100,000 10 years later, and C, Inc., paid $60,000 to receive income, if any, on $100,000 for 10 years.

Tax Benefits of Amortization

When the parties to a split purchase are unrelated, the present holder deducts the purchase price ratably over the duration of the term as we have seen. Although this eventually leaves the remainderman with a cost basis in the property equal to the purchase price of the remainder and, most likely, a large built-in gain, several tax benefits still result. 1. The holder of the present

interest receives ordinary

deduction currently. 2. The remainderman's built-in

gain, even if recognized on a

purely voluntary basis, in a

sale immediately after the

cessation of the present

interest, will be subject to tax 10

years after the initial purchase

and may be a long-term

capital gain. Capital gains have

historically been taxed at a

lower rate than ordinary

income. In any event, capital

losses, including carryovers,

are deductible from capital

gains without limit. 3. The conversion of ordinary

deductions currently into

capital gains later constitutes

an even better homemade tax

shelter if the remaindermen

adopt a "buy-and-hold"

strategy. 4. If the remaindermen retain

the property for life, any

builtin gains (or losses) disappear

on their death since the

successor in interest receives a

fair market value basis under

Section 101(a). 5. The advantages listed above

are only possible because the

automatic value increase in

the remainder with the mere

passage of time is not taxed

currently, as dividends or

otherwise, nor is there a

taxable distribution upon the

termination of the present

interest. Finally, no

dividend or liquidating

distribution results on the physical

transfer of the property to the

remainderman when their

remainder ripens into

complete ownership.

The Discount Rate

For tax purposes, the same discount rate is used to find the actuarial value of an annuity, a term interest, a life estate, a remainder and a revision. Under Section 7520, effective as of May 1989, the discount rate is determined monthly and is equal to the midterm applicable federal rate, rounded off to the nearest 2/10 of one percentage point. The rate in effect for the month a transaction occurs, e.g., a split purchase, a gift, a testamentary transfer, etc., is applied to the transaction and the original actuarially determined basis is frozen prospectively, regardless of subsequent changes in the rate.

The higher the discount rate the greater the value of a present interest (and the amortization deductions resulting from a purchase) and the lower the actuarial value of the future interest (the remainder), as shown in Figure 1.

Example: C, Inc., purchased a 10-year interest in land worth $100,000 and its two unrelated 50% shareholders the remainder as tenants in common. If in the month of acquisition the discount rate was 8%, C, Inc., must pay $53,680 for its term interest, resulting in an annual amortization deduction of $5,368. Had the discount rate been 12%, C, Inc.'s, cost would have been $67,800, increasing the annual deduction to $6,780.

The actuarial valuation is based on the assumption that the investment yields current income equal to the discount rate used. Thus, the actuarial value of a 10-year term interest is 61.45% at a rate of 10% because $100 invested at 10% yields $10 a year, and the present value of $10 a year for 10 years discounted at 10% equals $61.45.

On the other hand, given the discount rate, the present value of a term interest increases with the duration of the term as shown in Figure 2.(6)

Thus, increasing the term 100% from 10 to 20 years only increases the value of the interest 38.55%, from 61.45 to 85.14%. More importantly, the total amortization deduction is only increased by 38.55%, and the annual amortization is decreased from $6,145 a year to $4,257 a year, assuming a $100,000 price tag ($85,140/20).

Related Taxpayers

The amortization deduction is disallowed and added to the remainderman's basis only when the holders of the present and future interest are related in the Section 267(b) or (e) sense.(7) Thus, for example, the following taxpayers are related:

1. An individual and his or her

brothers, sisters, spouse,

ancestors and lineal descendants. 2. A grantor and the trustee of a

trust. 3. A trustee and a beneficiary of

a trust. 4. Two trustees of trusts with

the same grantor. 5. Trustees and beneficiaries of

trusts with the same grantor. 6. S corporations and their

shareholders and partnerships and

their partners.

Of special interest to corporations and their shareholders are the following sets of related taxpayers:

1. An individual and a

corporation, if the individual directly

and/or constructively owns

more than 50% of the value

of the corporation's stock.(8) 2. A corporation and a

partnership where the same person

owns more than 50% of the

value of the stock and more

than 50% of the capital

interest and/or the profit

interest.(9) 3. Two S corporations where more

than 50% of the value of both

is owned by the same

person.(10) 4. An S corporation and a C

corporation where the same

persons own more than half

the value of both.(11)

The 50% threshold may be exceeded by both actual and constructive ownership. Stock owned actually or constructively by corporations, partnerships, estates and trusts are deemed to be owned proportionately by shareholders, partners and beneficiaries.(12) An individual is deemed to own stock held, directly or indirectly, by or for his partner.(13) Entity attribution may be followed by family or partner attribution, but once stock ownership is obtained through family or partner attribution, such indirectly owned stock will not be reattributed to family members and partners.(14)

Family Attribution Examples

Example 1: A and his mother, M, both own 50% of C, Inc. Since A's stock is indirectly owned by M and vice versa, A and M are both related to C, Inc., as well as to each other.

Example 2: A and his mother, M, both own 25% of C, Inc. In addition, M's second husband, H, who is not A's father, owns 25% and an unrelated investor, I, owns the last 25%. M constructively owns 50% of C, Inc., her son's shares and her husband's shares, and is thus a 75% shareholder related to C, Inc. A only owns his own shares and the shares M owns directly for a total of 50% and is thus unrelated to C, Inc. M's constructive ownership of H's shares through family attribution is not reattributed to A.

Partner Attribution Examples

Example 1: A and B, two unrelated taxpayers, are business partners in that each owns half of the stock in C, Inc. Neither A nor B is related to C., Inc., for tax purposes.

Example 2: Same as Example 1, except that A and B are limited partners in the same real estate partnership. Regardless of the size of their partnership interest, e.g., 5% or 60%, A's stock is constructively owned by B and vice versa. As a result, A and B, A and C, Inc., and B and C, Inc., are all related taxpayers.

Common Corporate Ownership Example

A and B, two unrelated taxpayers, each own 50% of two C corporations. A and B are unrelated to either corporation, but the two corporations are related despite the fact that A and B are unrelated. The result is the same if one corporation is a C corporation and the other an S corporation.

Entity Attribution Example

C, Inc. is owned 25% by B, who is unrelated to A, 25% by a trust with A's daughter D as the income beneficiary, 25% by A's mother, M's estate with A's nephew, N, as the beneficiary of the stock and 25% by a grantor trust where A's father is the grantor. A constructively owns the 25% his daughter, D, owns indirectly through the trust and the 25% his father is deemed to own as the grantor of a grantor trust. A does not constructively own the shares in his mother's estate, since those shares are indirectly owned by his nephew, an unrelated taxpayer. Thus C, Inc. and A are unrelated since A only owns 50% of S, Inc. Similarly, D is only deemed to own the shares of the trust and her grandfather's shares, for a total of 50%. A's constructively owned 50% is not reattributed to D.

Unrelated Taxpayers

Taxpayers not defined as related under Section 267 are conclusively presumed to be unrelated for tax purposes. Thus, among others, the following pairs of taxpayers may engage in split purchases without having their amortization deductions disallowed:

1. An estate and an estate

beneficiary. 2. An individual and his nephew,

niece, aunt or uncle. 3. An individual and his in-laws,

including fathers and

mothers-in-law, brothers and

sisters-in-law, and sons and

daughters-in-law. 4. An unmarried couple, even if

they are living together. 5. A shareholder and a

corporation, as long as the

shareholder owns no more than

50% of the corporation's value,

directly and indirectly. 6. An individual and her

parent's second spouse (as long

as the individual is not adopted

by the latter). 7. Two beneficiaries of the same

trust (as long as they are

otherwise unrelated).

Example 1 -- Split Purchase Between Unrelated Taxpayers: C, Inc., purchases a 10-year term interest in property for $60,000 and its two unrelated 50% shareholders the remainder as tenants in common for $40,000. Each year C, Inc., amortizes $6,000 of its basis in the present interest, reducing its taxable income and earnings and profits. The basis in the remainder after 10 years is still $40,000, while the term interest and its basis are gone.

Example 2 -- Split Purchase Between Related Taxpayers: Same as Example 1, except the two shareholders are related, making C, Inc., related to both. Now, no deductions for amortization are allowed, but $6,000 of basis each year is transferred from C, Inc., to the shareholders. After 10 years the term interest and its basis no longer exist, but the shareholders have a $100,000 basis in the property, which they now own outright.

Spilt Purchase Compared With a Corporate Liquidation

One advantage of a corporate/shareholder split purchase is the potential saving of double taxation on a later corporate liquidation. This advantage may be illustrated through the use of the following somewhat oversimplified examples.

Example 1 -- Corporate Purchase, Later Liquidation: C, Inc., purchased land for $100,000 to be rented out as a parking lot. Ten years later it distributes the land, now worth $200,000, to its unrelated 50% shareholders, A and B, as a liquidating distribution. A and B have a basis of $50,000 each in their stock, having provided the funds to purchase the land originally. The tax consequences are as follows:

1. C, Inc., incurs a tax liability

of $34,000 (at a 34% assumed

rate) on the appreciation on

the land under Section 336

upon the liquidating

distribution. 2. A and B pay a combined tax

of $18,480 (at a 28% assumed

rate). The taxable gain is

$200,000 less the $34,000 of

corporate tax for which A and

B have transferee liability and

less their bases in their stock,

or $66,000 under Section 331. 3. A and B have a combined

basis of $200,000 in the land

under Section 334(a), but the

total tax bill is $52,480. 4. Any net rental income of C,

Inc., disregarded above, would

be subject to double taxation

as well, once at the corporate

level when earned, and once

upon distribution, whether as

a dividend and/or as an

additional liquidating


Example 2 -- Spilt Purchase, No Liquidation: Same as Example 1, except that A and B transfer $60,000 to C, Inc., which purchases a 10-year term interest in the land, while A and B purchase the remainder as tenants in common for $40,000. A and B's total investment is the same, $100,000. The tax consequences are as follows:

1. C, Inc., incurs no tax

liability after 10 years when A and

B receive the land as full

owners, since no liquidating

distribution takes place. 2. A and B report no gain when

C, Inc., dissolves. 3. A and B will have a

combined basis of only $40,000

in the land rather than

$200,000, but this built-in

gain may be postponed

indefinitely through a

retention of ownership or a

tax-free exchange. If held for life

the gain is never taxed since a

successor in interest receives

a stepped-up basis under

Section 1014(a). 4. The rental income of C, Inc.,

will be sheltered in full or in

part by the annual $6,000

amortization expense.

It should also be noted that the parking lot operation is not subject to the passive loss rules because of the exceptions for short-term rentals. Also, A and B still have a total basis of $60,000 in their stock, but a worthlessness deduction is doubtful since no loss has been actually sustained in the Section 165 sense.

Maximizing Expenses Paid by the Term Holder

To reduce taxable income and earnings and profits of the corporate holder of a term interest, the corporation should pay as many of the expenses of the property subject to a split purchase as possible. Under state law it is generally the obligation of the holder of the present interest to pay current operating expenses. Thus, if the property is a building, for example, the corporation would normally pay property taxes, mortgage interest, repairs and maintenance. When coupled with amortization and cost recovery deductions, the corporation's taxable income will be minimized.

Split Purchases of Stock With a C Corporation

If a C corporation purchases a term interest in income stock and one or more unrelated shareholders the remainder, a number of tax advantages may result, including increased, but partly sheltered, cash flows to the corporation and the tax-free transfer of assets to the shareholder.

Example: C, Inc., is owned equally by two unrelated shareholders, A and B. C purchases a 10-year term interest in preferred stock for $60,000 and the shareholders the remainder as tenants in common for $40,000. The dividend yield is 9%. The following noteworthy financial and tax consequences follow:

1. C collects $9,000 a year in

dividends, only $2,700 of

which is taxable due to the

70% dividend received

deduction under Section 243. 2. C amortizes its term interest

at the rate of $6,000 a year

for 10 years, which shelters

the taxable portion of the

dividend, plus $3,300 of

income from other sources. 3. After 10 years A and B own

the stock outright without

paying any tax on a dividend

or a liquidations distribution.

Since their basis is only

$40,000, a "buy-and-hold"

strategy is most appropriate.

Simultaneous Amortization and Cost Recovery

In cases where the property subject to a split purchase is depreciable, all depreciation or cost recovery is generally claimed by the holder of the term interest under Section 167(h). Even if Section 167(r) disallows the amortization deduction, cost recovery is still allowed under Section 167(r)(4)(B). Thus, where the parties to the split purchase are unrelated, both cost recovery of the property itself and amortization deductions of the basis in the term interest are allowable simultaneously. This has the effect of making accelerated depreciation available, even on buildings which can only be written off straight-line if placed in service after 1986. However, the sum of cost recovery and amortization can never exceed the total cost basis. In the examples below, the cost of land is disregarded for illustrative purposes.

Example 1 -- Cost Recovery: C, Inc., buys a 10-year term interest in an apartment building for $60,000 and A and B, its two 50% shareholders, the remainder for $40,000. C, Inc., will cost recover $100,000 over 27.5 years, straight-line, sheltering its income, whether the parties are related or not.

Example 2 -- Cost Recovery Plus Amortization: Same as Example 1, but both cost recovery and amortization are claimed since C, Inc., is unrelated to A and B. The annual cost recovery deduction is $3,636 ($100,000/27.5), 60% of which, or $2,182, reduces C, Inc.'s basis in the term interest, 40% of which, or $1,455, reduces A and B's basis in the remainder. C, Inc.'s amortization deduction the first year is therefore ($60,000-$2,182)/10, or $5,782. The total first year deduction is $9,418. Effectively, straight-line cost recovery has been converted to accelerated depreciation. After 10 years A and B own the building. Its adjusted basis equals $40,000 less 40% 10 year's cost recovery, ($40,000 - 10 x 1,455), or $25,450, to be cost recovered straight-line over the remaining 17.5 years.

Term Interests Held by Foreign or Tax-Exempt Taxpayers

If a split purchase is entered into by related parties the amortization expense is disallowed. Nevertheless, the remainderman is denied a basis increase in cases where the term interest is held by a foreign person or a tax-exempt organization, unless the term interest is effectively connected with the conduct of a U.S. trade or business.15 This is true even though the basis in the term interest is reduced by the disallowed deduction.16 The rule denies a taxable U.S. person a step-up in basis where the reduced basis in the term interest cannot be transformed into taxable gain.

Example 1: A corporation purchases a remainder in land for $40,000 and a related tax-exempt entity, such as a Section 401(a) pension plan, the term interest for $60,000. The corporation's basis is frozen at $40,000 even though the exempt entity's basis is reduced annually. This is a true "disappearing" basis situation.

Example 2: A foreign corporation purchases a term interest in a tract of land in the U.S., and its U.S. parent corporation purchases the remainder. Unless the land is effectively connected with a U.S. trade or business under Section 864(c)(2), the basis in the remainder is frozen, despite the annual reduction in the basis in the term interest without a deduction therefore.

Example 3: Same as Example 2 except that the foreign corporation makes a Section 882(d) election to treat its interest in the land as effectively connected with the U.S. trade or business. The U.S. parent corporation will then be allowed to increase its basis in the remainder by the disallowed amortization deductions.

Pass-Though of the Amortization Deduction to the Remainderman Employing a Conduit

When a conduit, e.g., an S corporation or a partnership, purchases the present interest and an unrelated the remainder, the shareholders may deduct the amortization expenses claimed by the pass-through entity.

Example -- Remaindermen Unrelated to Corporation: S, Inc., purchases a 10-year term interest in a $100,000 parking lot for $60,000, while two unrelated investors, C and D, acquire the remainder for $40,000 as tenants in common. The tax consequences are:

1. S collects rental income on

the full $100,000 for 10 years. 2. The rental income flows

through, as such, to its

shareholders A and B. 3. A and B's bases in their stock

is increased by the rental

income under Section

1367(a)(1)(A). 4. S deducts $6,000 of

amortization each year which flows

through to A and B, who are

more likely to be able to

utilize the deduction currently. 5. After 10 years C and D own

the real estate with a basis of

$40,000. 6. Upon sale C and D will

recognize a Section 1231 gain or

a long-term capital gain of

$60,000 plus/minus any value

change. Thus current

ordinary deductions have been

converted into long-term gain

later. To the extent C and/or

D keep the property for life,

the gain escapes income tax

permanently since the basis

of a successor in interest equals

the estate tax value under

Section 1014(a). 7. If A and B materially

participate in S, Inc.'s business, the

deductions are currently

deductible despite the

passive loss rules in Section 469.

In any event, $25,000 of losses

are available annually if A

and B actively participate in

the business under Section

469(i). 8. The 2% floor on

miscellaneous itemized deductions under

Section 67 should not apply

to rental expenses from an S


Example -- Shareholders Related to Corporation: A and B, two equal shareholders, form S, Inc., solely for the purpose of buying, holding and renting out a piece of nondepreciable property to be acquired for $100,000. The shareholders contribute $30,000 each, enabling S, Inc., to buy a 10-year term interest in the property for $60,000, then invest a further $20,000 each in the remainder in the property. Initially S, Inc., has a basis of $60,000 in the term interest, while the shareholders have a basis of $60,000 in the stock and $40,000 in the remainder.

Since A and B are shareholders, Section 167(r) applies. Therefore the amortization deduction of $6,000 a year is disallowed with the result that it reduces S, Inc.'s, basis in the term interest but is added to the basis in the remainder instead of being subtracted from the basis in the stock (and deducted from the shareholders income). Assuming that all income has been distributed and that S, Inc., has no other assets, after 10 years, S, Inc., is worthless, A and B own the property with a basis of $100,000, and their stock basis is still $30,000 each.

Since the stock is worthless, A and B may take the position that they each can deduct their $30,000 basis in the stock. Furthermore, the loss would be ordinary, in most cases, under Section 1244. The IRS is, however, likely to argue that A and B recovered their investment tax-free through basis increases in the underlying property. As a result no loss has been actually sustained, a threshold requirement for any loss deduction, under Section 165(a).

Sales of Remainder Interest

Case law is unanimous in stating that if a remainder in already acquired property is subsequently carved out and sold (or gifted), the retained term interest is not amortizable!17

Example: C, Inc., and A and B engage in a split purchase with C, Inc., buying a 10-year term interest for $60,000 and A and B the remainder for $40,000. C, Inc., may amortize the basis in the term interest. If, in an economically indistinguishable transaction, C, Inc., acquires the property for $100,000 then promptly sells the remainder to A and B for $40,000, the retained term interest is unamortizable. Section 167(r) is inapplicable, since no amortization is allowed even in the absence of Section 167(r). Thus, both bases are frozen at $60,000 and $40,000.

Sales of Term Interest

When a term interest in real estate is sold, the tax consequences are harsh. According to two Supreme Court cases, the amount received is taxable in full as prepaid rental income with no basis offset.(18) The buyer must amortize the cost of the term interest over its duration.

Example: C, Inc., purchased real estate for $100,000, then sold a 10-year term interest to A and B for $60,000. C, Inc., immediately recognizes rental income of $60,000, retains his $100,000 basis in the remainder, and A and B will deduct $6,000 a year if unrelated. If A and B are related, A and B wind up with a $160,000 basis in the property after 10 years since C, Inc., will be unable to amortize the basis in the term interest due to Section 167(r), and the disallowed deduction will be added to the basis of the remainder and subtracted from that of the term interest.


A major portion of the cost of an asset, even if nondepreciable, may be written off for tax purposes. To accomplish this, ownership must be split into a present and a future interest by purchase up front. After the Revenue Reconciliation Act of 1989, the owners of the present and future interests must be unrelated. Despite the restrictions and the basis disadvantages, writing off the cost of nondepreciable assets such as stocks may provide attractive tax savings in many different situations. Split purchases may be made by related individuals who are unrelated for tax purposes, between corporations and their shareholders (making dividends and liquidations less necessary), and between investors and their conduit entity (so as to pass the amortization deduction to the shareholders). The amortization of a term interest in property is one of the most attractive tax shelters still in existence. For many closely held corporations, split purchases may be a powerful weapon against double taxation, including double taxation resulting from the repeal of the General Utilities doctrine.


(1)Keitel v. Comm., 15 BTA 903 (1929), Bell v. Harrison, 212 F.2d 253 (CA-7, 1954), Rev. Rul. 62-132, 1962-2 CB 73. (2)Reg. 1.1014-5(c), Example 3. (3)Manufacturers Hanover Trust v. Comm., 431 F.2d 664 (CA-2, 1970). (4)Section 1014(a). (5)Section 167(r)(3)(A) and (B). (6)Reg. 20.2031-7(f), Table B. (7)Section 167(r)(5)(B). (8)Section 267(b)(2). (9)Section 267(b)(10). (10)Section 267(b)(11). (11)Section 267(b)(12). (12)Section 267(c)(1). (13)Section 267(c)(3). (14)Section 267(c)(5). (15)Section 167(r)(4)(A). (16)Section 167(r)(3)(A). (17)U.S. v. Georgia Railroad and Banking Co., 348 f. 2d 278 (CA-5, 1965), Gordon, 85 TC 309 (1980), Lomas Santa Fe, Inc., 74 TC 662 (1980), aff'd 693 f. 2d 71 (CA-9, 1982). (18)Reg. 1.61-8(b), Hort v. Comm., 313 U.S. 28 (1941), P.G. Lake, Inc., 356 U.S. 260 (1958).

Rolf Auster, PhD, LLM, CPA, is professor of taxation in the MS in taxation program in the School of Accounting at Florida International University in Miami. He is the author of numerous articles and several books on tax planning strategies.
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Author:Auster, Rolf
Publication:The National Public Accountant
Date:Jul 1, 1990
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