Section Newsletters

Articles From Michael L. English

Editor’s note By Michael L. English Real Estate Law, June 2009 An introduction to the issue from Editor Michael English.
Editor’s note By Michael L. English Real Estate Law, April 2009 An introduction to the issue from Editor Michael English. 
Editor’s note By Michael L. English Real Estate Law, March 2009 An introduction to the issue from Editor Michael English.
Editor’s note By Michael L. English Real Estate Law, February 2009 An introduction to the issue from Editor Michael English.
Editor’s note By Michael L. English Real Estate Law, January 2009 An introduction to the issue from Editor Michael English.
Editor’s note By Michael L. English Real Estate Law, December 2008 The current edition of the Real Estate Section Counsel Newsletter provides a compilation of materials of general interest to the real estate practitioner.
Editor’s note By Michael L. English Real Estate Law, October 2008 As some of you may know, Gary Gehlbach has been appointed to the position of Chairman of the Real Estate Law Section Council.
Corporate and partnership tax update By Michael L. English Federal Taxation, April 2003 In Seggerman Farms, Inc., 2002 TNT 207-5, the Seventh Circuit Court of Appeals, affirming the Tax Court, has held that shareholders of a family farm corporation must recognize gain on the transfer of assets to the corporation where the liabilities assumed by the corporation exceeds the adjusted basis of the property transferred.
Corporate and partnership tax update By Michael L. English Federal Taxation, November 2002 In Revenue Procedure 2002-22, the IRS announced conditions under which it would consider a request for a ruling that an undivided fractional interest in rental real property is not an interest in a business entity.
Recent developments in estate and gift tax By Michael L. English Trusts and Estates, November 2002 The tax court, in Christine M. Hackl, 118 T.C. No.14, ruled that gifts of ownership interests in a limited liability company did not qualify for the section 2503(b) annual gift tax exclusion where the ownership interests failed to confer substantial present economic benefits to the recipients.
Recent developments in estate and gift tax By Michael L. English Trusts and Estates, April 2002 The Chief Counsel's Office in Legal Memorandum 200141013 addressed the issue of a refund of estimated estate tax paid with a request for an extension of time to file a federal estate tax return.
Corporate and partnership tax By Michael L. English Federal Taxation, March 2002 1. Corporate compensation deduction denied. The Tax Court, in Tesco DriveAway Co., Inc., T.C. Memo. 2001-294, ruled that an accrual method corporation could not deduction compensation paid to related cash method taxpayers where the payments were made after the close of its fiscal year but prior to the end of the taxpayer's calendar year.
Recent developments in corporate and partnership tax By Michael L. English Federal Taxation, October 2001 In Seggerman Farms, Inc., T.C. Memo. 2001-99, the Tax Court ruled that the shareholders of a family corporation recognized gain on the transfer of assets to their controlled corporation where the liabilities assumed by the corporation exceeded the shareholders' adjusted basis in the property transferred.
Recent developments in estate and gift tax By Michael L. English Federal Taxation, June 2001 1. Service issues proposed regulations on ESBTs. The Service has issued proposed regulations on the qualification and treatment of electing small business trusts (ESBTs).
Recent developments on estate and gift tax By Michael L. English Federal Taxation, January 2001 The Service, in REG-106511-00, issued proposed regulations relative to the filing of an application for an automatic six month extension of time to file an estate tax return.
Corporate partnership update By Michael L. English Federal Taxation, October 2000 The Service, in Letter Ruling 200030018, ruled that a trust created for the purpose of holding non-voting stock of an S corporation was an eligible shareholder under section 1361(c)(2)(A)(i).
Editor’s note By Michael L. English Federal Taxation, February 2000 At the December 9, 1999 meeting of the Federal Taxation Section Council, it was announced that one of the members of the section council, Professor Karen V. Kole had accepted the position of Director of the Federal Tax Clinic of the Center for Law and Human Services (CLHS).
Editor’s note By Michael L. English Federal Taxation, November 1999 At the September 24, 1999, meeting of the Federal Taxation Section Council, the members of the council heard a guest presentation by Edith Siler, Senior Attorney with the Office of IRS District Counsel, in Chicago.
Corporate and partnership tax update­ August, 1999 By Michael L. English Federal Taxation, September 1999 In Craven v. U. S., 83 AFTR 2nd Par. 99-526, a Georgia District Court ruled that a stock redemption incident to a divorce was tax free under Code Section 1041.
Recent estate and gift tax cases, rulings and regulations—the stuff that there was not enough time in the day to read By Michael L. English Trusts and Estates, April 1999 Letter Ruling 9842003 continues the recent Service assault on valuation discounts for transfers to family limited partnerships which are created or funded shortly prior to death.

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