In a recent Tax Notes Federal article, tax associate Bob Kane examines Pope & Talbot and argues that the IRS has inappropriately relied on that case in two rulings addressing the calculation of section 311 gain on distributions of partnership equity. Please click here to read the full article
Tax associate Bob Kane authored an article published by Tax Notes Federal that examines whether Example 9 of reg. section 1.1361-5(b)(3) governs the disposition of a qualified subchapter S subsidiary in a nonrecognition transaction.
Please click here to read the full article.