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Article Title

Federal Taxation

Publication Date

7-2011

Document Type

Survey Article

Abstract

This Article surveys certain federal tax cases decided by courts in the Eleventh Circuit in 2010. There were no significant decisions. The case of Ocmulgee Fields, Inc. v. Commissioner addressed the applicability of section 1031(f)(4) of the Internal Revenue Code (I.R.C.) to likekind exchanges. The case of United States v. Fort involved a partner who, in exchange for his interest in an acquired partnership, received shares of the acquiring corporation subject to certain restrictions. The issue was whether the restrictions permitted the partner to exclude the shares from gross income when received. The case of Southern Family Insurance Co. v. United States addressed whether "takeout bonuses" paid by a state to an insurance company were included in gross income or excluded from gross income as nonshareholder contributions to capital.

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