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More About This Title Bankruptcy and Insolvency Taxation, 3rd Edition 2008 Cumulative Supplement
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Dr. Newton was a member of the AICPA’s Task Force on Financial Reporting by Entities in Reorganization Under the Bankruptcy Code that resulted in the issuance of the Statement of Position 90-7. He is coauthor of Consulting Services Practice Aid 02-1: Business Valuation in Bankruptcy and Providing Bankruptcy & Reorganization Services—Practice Aid, both published by the AICPA. He serves as a consultant and expert witness on issues dealingwith financial reporting during and emerging from chapter 11, valuation, terms of plan, tax impact of plan, tax issues related to the bankruptcy estate, and recovery of assets.
Robert Liquerman is a principal in KPMG LLP’s Washington National Tax Practice, Corporate Tax Group, specializing in matters under Subchapter C of the Internal Revenue Code. He is an adjunct professor of law in the LL.M. program at the Georgetown University Law Center and previously served as an adjunct professor in the LL.M. program at The College of William & Mary, Marshall-Wythe School of Law.
Mr. Liquerman holds an LL.M. in Taxation from New York University School of Law, a J.D. from St. John’sUniversity School of Law, and a B.S. in Accounting from the State University of New York at Binghamton.
He joined KPMG LLP from the Internal Revenue Service Office of the Chief Counsel, Corporate Division. In this position, he drafted treasury regulations, private letter rulings, technical advicememoranda, closing agreements, responses to congressional inquiries, field service advice, and memoranda of law. Prior to his government experience, Mr. Liquerman was a senior tax associate in the mergers and acquisition group and the insurance group in the New York office of Coopers & Lybrand.
He is a frequent speaker on bankruptcy and tax issues at various tax institutes and conferences around the country, including Tax Executives Institute, Federal Bar Association, DC Bar Association, and the Association of Insolvency and Restructuring Accountants. Mr. Liquerman is a member of the American Bar Association, Section of Taxation.
Although Chapters 2, 5, 6, and 7 reflect the views of Robert Liquerman, they do not necessarily reflect the views of KPMG LLP.
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Preface.
Acknowledgments.
Chapter One: Nature of Bankruptcy and Insolvency Proceedings.
§ 1.1 Objectives.
*§ 1.2 Alternatives Available to a Financially Troubled Business.
Chapter Two: Discharge of Indebtedness.
*§ 2.3 Determination of Discharge of Indebtedness Income.
*§ 2.4 Section 108(e) Additions to Discharge of Indebtedness Income.
*§ 2.6 Discharge of Indebtedness Income Exclusions.
*§ 2.8 Use of Property to Cancel Debt.
*§ 2.9 Consolidated Tax Return Treatment.
Chapter Three: Partnerships and S Corporations: Tax Impact of Workouts and Bankruptcies.
§ 3.2 Partnerships.
§ 3.3 S Corporations.
Chapter Four: Taxation of Bankruptcy Estates and Debtors.
§ 4.3 Accounting for the Bankruptcy Estate.
§ 4.4 Accounting for the Debtor (Individual).
Chapter Five: Corporate Reorganizations.
*§ 5.2 Elements Common to Many Reorganization Provisions.
§ 5.4 Acquisitive Reorganizations.
*§ 5.5 Stock Acquisitions.
*§ 5.6 Single Entity Reorganizations.
§ 5.7 Divisive Reorganizations.
*§ 5.8 Insolvency Reorganizations.
Chapter Six: Use of Net Operating Losses.
*§ 6.2 I.R.C. Section 381.
*§ 6.4 Current I.R.C. Section 382.
§ 6.6 I.R.C. Section 384.
§ 6.9 Consolidated Return Regulations.
Chapter Seven: Other Corporate Issues.
§ 7.3 Incorporation.
§ 7.4 Liquidation.
§ 7.5A A Limited Liability Corporation (LLC) (New).
Chapter Eight: State and Local Taxes (Revised).
*§ 8.1 Introduction.
§ 8.2 Bankruptcy Estates.
§ 8.3 Stock for Debt.
§ 8.4 Cancellation of Indebtedness.
§ 8.5 Net Operating Loss Carryback and Carryover.
*§ 8.6 Stamp Tax (New Title).
*§ 8.7 Tax Impact of Plan for State and Local Purposes (New).
Chapter Nine: Tax Consequences to Creditors of Loss from Debt Forgiveness.
§ 9.3 Business and Nonbusiness Losses.
Chapter Ten: Tax Procedures and Litigation.
*§ 10.3 Tax Determination.
Chapter Eleven: Tax Priorities and Discharge.
§ 11.2 Priorities.
*§ 11.3 Tax Discharge.
Chapter Twelve: Tax Preferences and Liens.
§ 12.2 Tax Preferences.
*§ 12.3 Tax Liens.
Appendix F.1: Tax Changes to Bankruptcy Code by 2005 ACT (New).
Appendix F.2: Bankruptcy Abuse Prevention and Consumer Protection Act of 2005 (New).
*Appendix F.3: Notice 2006-83; 2006-2 C.B. 596; 2006 IRB LEXIS 518; 2006-40 I.R.B. 596 (New) September 18, 2006.
*Appendix G: Official Form 22A (Chapter 7)(1/08)(New).
Statutes Citations.
Treasury Regulations, Revenue Procedures, and Revenue Rulings Citations.
Case Index.
Subject Index.
