BIBLIOGRAPHY OF SELECTED ARTICLES ON FEDERAL ESTATE AND GIFT TAX REFORM The listing of articles in this bibliography does not represent approval by the Committee on Ways and Means or its staff of any author, analysis or opinion in the included articles. Moreover, this bibliography does not purport to be exhaustive, but is intended solely to provide Members of Congress and their staffs with a convenient introduction to the voluminous literature on the reform of the Federal estate and gift tax laws. ABBIN, "Significant Recent Developments Concerning Estate Planning-1975." 75 The Tax Adviser 166, 220, 277 (1975). AMERICAN BAR ASSOCIATION, Committee on Estate and Gift Taxes, "Tax Section Recommendation No. 1974-2, To Amend the Internal Revenue Code of 1954 To Provide for Estate and Gift Tax Treatment of Disclaimers," 27 Tax Lawyer 818 (1974). ANDREWS, "The Accessions Tax Proposal." 22 Tax Law Review 589 (1967). BITTKER, "Federal Estate Tax Reform: Exemptions and Rates." Hearings on General Tax Reform Before the House Committee on Ways and Means, 93d Cong., 1st sess., pt. 10, p. 4186. BLUM and PEDRICK, "Reform School Approach to Estate and Gift Tax Revision." 51 Taxes 81 (1973). CHABBOW, "Estate and Gift Tax Reform-Reform For Reform's Sake?" 110 Trust & Estates 254 (1971). CHAFFIN, "Restructuring Federal Estate and Gift Taxes: Impact of Proposed Reforms on Estate Planning." 69 Michigan Law Review 211 (1970). CHOWN, "Capital Transfer Tax in the United Kingdom." 23 Canadian Tax Journal 494 (1975). COLLIE, "Estate and Gift Tax Revision." 26 National Tax Journal 441 (1974). "Prospect For Estate and Gift Tax Revision." 20 Tulane Tax Institutes 59 (1971). "Contemporary Studies Project: Large Farm Estate Planning and Probate in Iowa." 59 Iowa Law Review 794 (1974). COVEY, "Estate and Gift Tax Revision." 26 National Tax Journal 459 (1974). "Possible Changes in the Basis Rule For Property Transferred by Gift or at Death." 50 Taxes 831 (1972). COVEY, SURREY, and WESTFALL, "Perspectives on Suggested Revisions in Federal Estate and Gift Taxation." 28 Record of New York City Bar Association 42 (1973). "Perspectives on Suggested Revisions in Federal Estate and Gift Taxation." 112 Trust & Estates 102 (1973). DANE, "Federal Estate and Gift Tax Reform." 108 Trusts & Estates 783 (1969). DONAHUE, "Prospective Tax Reform: What We May Expect and How We Can Plan For It." 29 New York University Institutes on Federal Taxation 1773 (1971). DRAKE, "Federal Estate and Gift Taxes: A Legislative History, a Description of Current Law, a Discussion of Major Reform Proposals and a Selected Bibliography." Library of Congress, Congressional Research Service, multilith 74-123E (1974). EISENSTEIN, "The Rise and Decline of the Estate Tax." 11 Tax Law Review 223 (1956). EMORY, "The Corman and Mills-Mansfield Bills: A Look at Some Major Tax Reform Issues." 29 Tax Law Review 3 (1973). "Federal Estate and Gift Tax Reform." 6 Real Property & Trust Journal 222 (1970). GRAETZ, Statement on Estate and Gift Tax Revision, Hearings on General Tax Reform Before the House Committee on Ways and Means, 93d Cong., 1st sess., pt. 8, p. 3363. HARRISS, Statement on Estate and Gift Tax Revision, Hearings on General Tax Reform Before the House Committee on Ways and Means, 93d Cong., 1st sess., pt. 10, p. 4186. "Prospects and Principles for Estate Tax Revision." 69 New Jersey State Bar Journal 30 (Nov. 1974). JANTSCHER, "Death and Gift Taxation in the United States After the Report of the Royal Commission." 22 National Tax Journal 121 (1969). KINNEBREW, "Estate and Gift Tax Reform: A Compendium of Thought." 24 Southwestern Law Journal 608 (1970). KRAMER, "The Federal Estate and Gift Tax Laws-Reform for Modernization," in The Taxpayers' Stake in Tax Reform 10 (U.S. Chamber of Commerce: 1968). KURTZ, "Federal Estate and Gift Tax Changes: Some Arguments in Favor of Treasury's Proposals." 108 Trusts & Estates 458 (1969). KURTZ and SURREY, "Reform of Death and Gift Taxes: The 1969 Treasury Proposal, the Criticisms and a Rebuttal." 70 Columbia Law Review 1365 (1970). LLEWELLYN, "Estate and Gift Tax Reform: Inter Vivos Transfers With a Testamentary Flavor." 13 William and Mary Law Review 553 (1972). MCDONALD, "Unsatisfied at Any Price." 21 Tax Lawyer 329 (Winter, 1968). MEIBURGER, "Note: Current Suggestions For Gift and Estate Tax Legislation." 30 Tax Law Review 451 (1975). NORTH, "Estate and Gift Tax Reform." 110 Trusts and Estates 22 (1971). PESCHEL, "Salvaging the S.S. Estate and Gift Tax: A Glimpse at Transfer Tax Reform." 45 Tulane Law Review 510 (1971). SEIDMAN, "Status of Federal Estate and Gift Tax Legislative Proposals.” 51 Taxes 197 (1973). SHOUP, "Federal Estate and Gift Taxes." (The Brookings Institution: 1966). SOMERS, "The Case for a Capital Gains Tax at Death." 52 American Bar Association Journal 346 (1966). THIES, "Some Hard Questions About Estate and Gift Tax Reform." 109 Trusts & Estates 465 (1970). WESTFALL, "Revitalizing the Federal Estate and Gift Taxes." 83 Harvard Law Review 986 (1970). WOODS, "Increasing Impact of Federal Estate and Gift Taxes on the Farm Sector: Present Law and Proposed Changes." Agricultural Economic Report No. 242 (U.S. Department of Agriculture: 1973). WOODS, GUITHER, and KYLE, "Death and Taxes: Policy Issues Affecting Farm Property Transfers." North Central Regional Extension Publication No. 40 (University of Illinois: 1973). WORMSER, "The Case Against a Capital Gains Tax at Death." 51 American Bar Association Journal 851 (1965). YOUNG, "Proposed Revisions of the Federal Estate and Gift Tax System: The ALI Revisited." 6 Georgia Law Review 75 (1970). SUBJECT INDEX Glossary of abbreviations used in this index : Admin=Proposal contained in President's Alternate valuation, ABA 606 Annuities ALI 337, ABA 608 ESTATE TAX see completed v. uncompleted gifts ALI 363, ABA 553 Charitable transfers Collie 78, Westfall 117, Covey 138, Treas 223, ALI 343, ABA See disclaimer ALI 361, ABA 602 Credit for gift tax completed v. uncompleted gifts ALI 363, ABA 553 Credit for state death taxes Lewis 86, Westfall 123 Credit for tax on prior transfers ALI 345, AICPA 652, 653 Disclaimer Lewis 86, ALI 361, ABA 602, AICPA 650 sec powers of appointment ALI 340, charitable transfers ALI 343, Dual tax system v. unified transfer tax ALI 377 Exemption Westfall 114, Covey 131, ALI 371, ABA 384, 395, 592, AICPA 695 Generation-skipping transfers Collie 76, Lewis 84, Brown 101, Westfall 118, Interspousal transfers marital deduction Collie 77, Lewis 85, Brown 100, Westfall 116, Covey 137, see gift splitting transfers ALI 359, disclaimer ALI 361, transition terminable interest rule Lewis 85, Westfall 117, Brannon 151, ALI 353, ABA Joint interests Lewis 86, ALI 333, ABA 508 Liability for payment apportionment of tax ABA 627 moratorium ABA 401 Life insurance Lewis 86, Westfall 122, Covey 140, ALI 339, ABA 611 see completed v. uncompleted gifts ALI 363, ABA 553 Liquidity Admin 65, Covey 141, Brannon 152, Westfall 156, Collie 157, Treas 202, Payment of estate tax with government securities Treas 308 Powers of appointment Collie 77, ALI 340, ABA 515 Power of appointment Collie 77, ALI 340, ABA 515 Property in which decedent had an interest ABA 607 Rate of tax Lewis 86, Westfall 108, Covey 131, Treas 224, ALI 369, ABA 478, Revocable transfers completed v. uncompleted gifts ALI 363, ABA 553 Taxation of appreciation at death additional estate tax Covey 128, ABA 482, 519 capital gains at death Collie 73, Brown 92, Westfall 109, Covey 128, Brannon carryover basis Collie 73, Brown 96, Westfall 113, Covey 128, Brannon 149, Taxation of appreciation at death-Con. general comments AICPA 662 see rate of tax AICPA 683, interspousal transfers AICPA 685, charitable transfers AICPA 685 Transactions in contemplation of death completed v. uncompleted gifts ALI 363, ABA 553 Transfer for consumption ALI 341 Transfers taking effect at death completed v. uncompleted gifts ALI 363, ABA 553 Transfers with retained life estate completed v. uncompleted gifts ALI 363, ABA 553 Annuities GIFT TAX employee death benefit ALI 337 Charitable transfers Treas 223, ALI 343, ABA 594 Disclaimer ALI 361, ABA 602 Exclusion Westfall 116, Treas 253, ALI 373, ABA 590, AICPA 695 see transition problems ALI 374 Gift-splitting transfers Westfall 116, ALI 359 see marital deduction ALI 353, ABA 568 Interspousal transfers marital deduction Treas 199, 204, 217, 225, 251, ALI 353, ABA 568 Powers of appointment ALI 340, ABA 515 Rate of tax Collie 75, ALI 369, AICPA 694 see transition problems ALI 374 Taxation of appreciation of assets transferred by gift Treas 198, 203, 213, 224, 231 UNIFIED TRANSFER TAX Annuities Treas 263, 276, ALI 337, ABA 608 Charitable transfers Treas 223, 266, 281, ALI 343, ABA 594 Dual tax system v. unified transfer tax ALI 377, ABA 391 General comments Collie 74, Lewis 82, Brown 98, Westfall 113, Covey 135, Brannon Generation-skipping transfers Treas 201, 204, 222, 226, 288, ALI 348, ABA 518 Gifts in contemplation of death Treas 261, AICPA 695 Interspousal transfers Treas 199, 204, 217, 225, 257, 277, ALI 353, ABA 568, AICPA Joint interests Treas 263, 275, ALI 333, ABA 508 Liability for tax Treas 271 Life insurance Treas 262, 273, ALI 339, ABA 611 Liquidity Treas 202, 205, 224, 228, 301, ABA 630 Orphan exclusion Treas 200, 204, 266, 281 Powers of appointment Treas 262, 273, 286, ALI 340, ABA 602 Rate of tax Treas 202, 205, 226, 255, 269, ALI 369, ABA 478, AICPA 694 Taxation of appreciation at death or by gift Treas 198, 203, 213, 224, 231 Transfer for consumption ALI 341 Transfer with retained life estate Treas 264, 284 Transfer with reversionary interest retained Treas 264, 285 Transition problems Treas 268, 287, ALI 374 |