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INTRODUCTION 3
COMPUTATION OF INCOME TAX 5
IS IT INCOME? 5
NONCASH BENEFITS DEFAULT 5
Self-Assessment, Audits, and Tax Litigation 5
The Sources of Federal Tax Law in a Nutshell 6
MEALS AND LODGING PROVIDED TO EMPLOYEES 6
Noncash Benefits and 1. Meals and Lodging Provided to Employees 7
Glenshaw Glass and Accompanying Notes 8
Other Fringe Benefit Statutes 8
IMPUTED INCOME 11
WINDFALLS 13
BASIC GIFTS 14
COMPLICATIONS RELATED TO GIFTS 18
RECOVERY OF CAPITAL 20
LIFE INSURANCE 22
ANNUITIES 23
GAMBLING 25
RECOVERY OF LOSS 26
Deferred Payments and Structured Settlements 30
Medical Expenses and Other Recoveries and Benefits 30
TRANSACTIONS INVOLVING LOANS 33
DISCHARGE OF INDEBTEDNESS 33
PART-GIFT, PART-SALE 37
ILLEGAL INCOME 43
INTEREST ON STATE AND LOCAL BONDS 44
GAIN ON THE SALE OF A HOME 46
TIMING 49
TIME VALUE OF MONEY 49
GAINS AND LOSSES FROM INVESTMENT IN PROPERTY 50
REALIZATION DOCTRINE 50
STATUTORY NON-RECOGNITION PROVISIONS 53
LIKE-KIND EXCHANGES 55
TRANSFERS INCIDENT TO MARRIAGE AND DIVORCE 62
Property Settlements 63
Antenuptial Settlements 65
Alimony, Child Support, and Property Settlements 66
ORIGINAL ISSUE DISCOUNT 68
OPEN TRANSACTIONS AND INSTALLMENTS SALES 74
Open Transaction 75
The Installment Method 76
CONSTRUCTIVE RECEIPT AND RELATED DOCTRINES 78
STOCK OPTIONS AND OTHER RESTRICTED PROPERTY 84
ACCRUAL METHOD TAXPAYERS 92
STRUCTURED SETTLEMENTS 95
PERSONAL DEDUCTIONS, EXEMPTIONS, AND CREDITS 99
CASUALTY LOSSES 99
MEDICAL EXPENSES 104
CHARITABLE CONTRIBUTIONS 106
ALLOWANCE FOR MIXED BUSINESS AND PERSONAL OUTLAYS 111
CONTROLLING THE ABUSE OF BUSINESS DEDUCTIONS 111
Hobby Losses 112
Home Offices and Vacation Homes (p. 400): 113
Child Care Expenses: 117
TRAVEL AND ENTERTAINMENT EXPENSES 119
COMMUTING EXPENSES 123
CLOTHING EXPENSES, LEGAL EXPENSES, EXPENSES OF EDUCATION 126
Clothing Expenses 126
Legal Expenses 127
Education Expenses 128
DEDUCTIONS FOR THE COSTS OF EARNING INCOME 131
CURRENT EXPENSES VERSUS CAPITAL EXPENDITURES 131
REPAIR AND MAINTENANCE EXPENSES 136
INVENTORY ACCOUNTING 137
RENT PAYMENT VS. INSTALLMENT PURCHASE 138
“ORDINARY AND NECESSARY” 141
Extraordinary Behavior: 141
Reasonable Compensation (p. 502) 142
Costs of Illegal or Unethical Activities: 142
DEPRECIATION AND AMORTIZATION AND CRANE AND TUFTS 144
CAPITAL GAINS AND LOSSES 153
INDEX 167

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