This Month's Features:
- Final "COD income" regulations on partnership issuance of capital or profits interest to a creditor in satisfaction of debt
- Temporary and proposed regulations on basis allocations in "All Cash D" reorganizations
- Proposed regulations under section 382 for "Small Shareholders"
- Proposed regulations defining "interest in a limited partnership as a limited partner"
- Southgate Master Fund LLC v. United States: Fifth Circuit denies rehearing request