Calvin H. Johnson, John T. Kipp Chair in Corporate and Business Law at the University of Texas Law School, has published his article, Cut Negative Tax Out of Step Up at Death.  The Abstract is as follows:

In this article, Johnson argues that Congress should exclude double deductions and negative taxes from the step-up in basis under section 1014. This proposal is the first of three Shelf Projects designed to prune back the basis step-up under section 1014. The Shelf Project is a collaboration of tax professionals to propose and perfect ideas to protect and develop methods for raising revenue in ways that improve the fairness and efficiency of the tax system. This is the 79th Shelf Project proposal.

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Posted by Lewis J. Saret, Co-General Editor, Wealth Strategies Journal.