Richard M. Lipton

February 25, 1952

Youngstown, Ohio, United States

Worked at Sonnenschein Nath & Rosenthal (Chicago, Illinois) specializing in Federal and State Income Taxation. Admitted to the bar, 1977, Illinois and United States. Tax Court; 1978, District of Columbia. 1980, United States. Claims Court. Order of the Coif. Associate Editor, University of Chicago Law Review, 1976-1977. Author: "Just When Will Environmental Clean-Up Expenditures Be Deductible?" The Journal of Taxation, February, 1996. "Divided Tax Court Applies INDOPCO To Hostile Takeovers," The Journal of Taxation, January, 1996. "State Seeks to Widen Tax Jurisdiction Over Out-of-State Companies," The Journal of Taxation, December, 1995. Company-Author: "Restrictive Proposed Regulations on Publicly Traded Partnerships Could Cause Any Partnership to be Taxed as a Corporation," (with Leslie H. Loffman, and Sanford C. Presant) The Tax Magazine, TAXES, September, 1995. Author: "The Partnership Anti-Abuse Regs. Revisited: Is There Calm After the Storm?" The Journal of Taxation, August, 1995. "Internal Revenue Service Improves Partnership Anti-Abuse Regs., but Major Problems Remain," The Journal of Taxation, March, 1995. Proposed Regulations Address Relief for Real Estate Professionals Under the Passive Loss Rules," The Tax Magazine, TAXES, March, 1995. "Tax Consequences of Business and Investment-Driven Uses of Derivatives," The Tax Magazine, TAXES, December, 1994. "Internal Revenue Service Addresses Tax Treatment of Partnership Distributions of a Partner"s Debt or Stock," The Monthly Digest of Tax Articles, June, 1994. "The Final Section 704 (c) Regulations: The Good and the Bad," Journal of Real Estate Taxation, Summer, 1994. "Choice of Entity: How To Choose, How to Change," Taxes, June, 1994. "Controversial Partnership Anti-Abuse Propagation Regs. Raise Many Questions," Journal of Taxation, August, 1994. "Insolvent Partner Taxed on Partnership"s COD Income Despite Code Provision," Journal of Taxation, October, 1994. "Passive Loss Audit Guidelines Highlight Issues for Taxpayers," Taxes, October, 1994. "Internal Revenue Service Challenges South Corporation Basis Increase for COD Income," Journal of Taxation, December, 1994. Company-Author: "Expenses Related to Failed Merger Defense Held to Be Deductible Despite INDOPCO," with Ryan Brenneman, Journal of Taxation, January, 1995. Author: "Internal Revenue Service Improves Partnership Anti-Abuse Regs., But Major Problems Remain," Journal of Taxation, March, 1995. "RRA "93 Liberalizes Passive Loss Restrictions for Real Estate Professions," 11 Journal of Partnership Taxation 15 (1994). "Further Developments Concerning Passive Losses," 72 Taxes 136 (1994). "How to Avoid Capital Loss Treatment on the Abandonment of a Partnership Interest," 80 Journal of Taxation 158 (1994). "New Rules Address Capital Gains on Some Investments," 72 Taxes 51 (1994). "Internal Revenue Service Issues New Regulations on Hedging Transactions," 72 Taxes 3 (1994). "1993 Tax Legislative Changes to the Passive Activity Loss Rules," 71 Taxes 611 (1993). "Proposed 1398 Regs. Raise Conflict Between Debtors and Bankruptcy Trustees," 79 Journal of Taxation 12 (1993). "UPREITs: Fad or Fixture?" 71 Taxes 395 (1993). "Final Regs. Simplify the Rules for Acquisitions of Debt by Related Parties," 78 Journal of Taxation 196 (1993). "Internal Revenue Service Addresses Tax Treatment of Partnership Distributions of a Partner"s Debt or Stock," 71 Taxes 187 (1993). "Internal Revenue Service Issues Proposed Regulations on Debt Modifications," Taxes, February 1993. "New Rulings on Purchase Price Reductions Do Not Provide Much Relief," The Journal of Taxation, February 1993. "Internal Revenue Service Addresses Cancellation of Debt Income Under Partnership and Passive Activity Rules," The Journal of Taxation, January 1993. "Tax Planning Foreign NonCorporate Bankruptcies," Taxes, October 1992. "Internal Revenue Service Adopts Inconsistent Positions on Nonrecourse Debt," The Journal of Taxation, October 1992. ""Thumbs Up" for The Proposed Activity Regulations," Taxes, July, 1992. "Planning for Non-corporate Debt Workouts Outside of Bankruptcy," Taxes, May 1992. "The Application of Section 469 To Real Estate Developers: The Search for a Solution to a Problem That Should Not Exist," Tax Notes, March 1992. "Internal Revenue Service Attacks Hospital Joint Ventures," Taxes, February 1992. "The Tax Consequences to a Debtor from a Transfer of Its Indebtedness," TAXES - The Tax Magazine, December, 1991. "The Single-Class-of-Stock Regulations, Round Two: The Internal Revenue Service Retreats," The Journal of Taxation, November, 1991. "The Internal Revenue Service "Fixes" the Developer Rule," The Journal of Real Estate Taxation, Fall, 1991. "PALs at Four: Living with the Regulations," TAXES - The Tax Magazine, November, 1990. "Internal Revenue Service "Fixes" the Developer Rule," 19 Journal of Real Estate Taxation, 1991. "Deferred Exchanges Easier Under Final Regs.," 47 Taxation for Accountants 76, 1991. "Regs. Increase Gain Potential If Related Party Acquires Debt," 74 Journal of Taxation 354, 1991. "Section 1274 and COD Income Due to Modification of the Interest Rate in a Debt Instrument," 68 TAXES504-519, 1990. "Internal Revenue Service Eases Passive Loss Limitation Foreign Casualty Losses," 68 TAXES363-367, 1990. "The Activity Regulations: Playing New Games with Building Blocks," 67 TAXES411-437. "PALs at Three: What We Know, What We Don"t Know and What Went Wrong," 67 TAXES715-734, 1989. "Corporate PALs: The Impact of the New Activity Regulations on C Corporations," 2 Corporate Taxation 11-19, 1989. "Changing PALs: Amendments To The First Secretariat of Passive Activity Loss Regulations," 67 TAXES502-511, 1989. "North American Palladium Ltd Material Participation Rules Harbor Unpleasant Surprises for Corporations," Volume 1, Number. 6, Corporate Taxation, 5-10, 1989. "PALs at Two: What We Know and Don"t Know About Passive Activity Losses on Their Second Birthday," 66 TAXES833-850, 1988. "Notice 88-94: A Flexible Transnational Rule for the Definition of and Activity," 66 TAXES658-662, 1988. "The Effect of Internal Revenue Service Notice 88-75 on PTPs," 40 Tax Notes 747-757, 1988. "More Fun and Games with PALs: The First set of Section 469 Regulations," 66 TAXES235-261, 1988. "Publicly Traded Partnerships and the 1987 Acting," 38 Tax Notes 183-186, 1988. "Passive Activity Loss Limitations Can Have Unexpected Impact on Corporations," 68 Journal of Taxation 20-29, 1988. "What We Do and Don"t Know About PALs," 37 Tax Notes 429-439, 1987. "Fun and Games with our New PALs," 64 TAXES801-813, 1986. "Tax Court Explores The Boundaries Of Material Participation In Passive Activities," The Journal of Taxation, December, 1996. "The Section 1001 Debt Modification Regulations: Problems and Opportunities," The Journal of Taxation, October, 1996. "Proposed Check-The-Box Business Classification Regulations Simplify Current Rules," Journal of Partnership Taxation, Fall, 1996. "Partnership Deemed Terminations Will Be Simpler Under New Proposed Regulations," The Journal of Taxation, September, 1996. "Tax Administration in the 90s: An Agenda to Limit Legitimate Tax Planning Techniques," The Tax Magazine, TAXES, April, 1996. "Divided Tax Court Allows Deduction of Interest on Tax Arising From a Trade or Business," The Journal of Taxation, April, 1996. "Internal Revenue Service Issues Final Regulations on Passive Loss Relief for Real Estate Professionals," The Tax Magazine, TAXES, February, 1996. Company-author: "The Single-Class-of-Stock Rules, Round Three: The Final Regulations (with Michael Fondo)," The Journal of Taxation, September 1992. "Supreme Court Approves Focus on Long-Term Benefit in Takeover Expense Controversy," (with Lynn A. Schewe and Michael C. Fondo) The Journal of Taxation, June 1992. "Campbell-is The Volcano Really Dormant Again?" (with Thomas M. Stephens) Journal of Taxation of Investments, March 1992. (with Lynne A. Schewe) "New Propagation Regs. Limit Disguised Sales Through the Use of Partnerships," Corporate Taxation, September/October, 1991. (with Thomas M. Stephens and Louis South. Freeman) "Regs. Increase Gain Potential If Related Party Acquired Debt," The Journal of Taxation, June, 1991. (with Lynne A. Schewe and Louis South. Freeman) "How to Establish Deductions for Friendly Takeover Costs by Limiting National Starch," The Journal of Taxation, March, 1991. (with David Evaul) Passive Activity Losses, (Little Brown 1995). "Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions," with Leslie H. Loffman and Sanford C. Presant, The Journal of Taxation, May, 1996. Adjunct Professor of Taxation, Chicago-Kent College of Law, 1990-1992. Lectures for 1993-1994: American Bar Association. Southern Federal Tax Conference. ALI/American Bar Association. New York University Real Estate Institute. Indiana Society of Certified Public Accountants"son American Federal Tax Institute. College of William & Mary. Heart of America Tax Institute. Chicago Federal Tax Forum. University of Chicago Tax Conference. Maryland Institute on Continuing Legal Education. Law Clerk to Judge Cynthia H. Hall, United States. Tax Court, 1977-1979. Member: Chicago (Chair, 1991-1992. Vice-chair, 1990-1991, Secretary, 1989-1990, Member, Executive Committee, 1983-1990, Chair, General Tax Division, 1983-1985, Federal Taxation Committee) and American (Section of Taxation: Vice Chair, 1993. Council Director, 1990-1993, Chair, Task Force on Passive Activity Losses, 1986-1990, Chair, Committee on General Income Tax Problems, 1987-1989. Vice Regional Liaison, 1989-1990).

Richard M. Lipton

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Background

Lipton, Richard M. was born on February 25, 1952 in Youngstown, Ohio, United States. Son of Sanford Y. Lipton and Sarah (Kentor) Goldman.

Education

Amherst College (Bachelor of Arts, cum laude, 1974). University of Chicago (Juris Doctor, with honors, 1977). Order of the Coif. Associate Editor, University of Chicago Law Review, 1976-1977.

Career

Worked at Sonnenschein Nath & Rosenthal (Chicago, Illinois) specializing in Federal and State Income Taxation. Admitted to the bar, 1977, Illinois and United States. Tax Court; 1978, District of Columbia.

1980, United States.

Claims Court. Order of the Coif. Associate Editor, University of Chicago Law Review, 1976-1977. Author: "Just When Will Environmental Clean-Up Expenditures Be Deductible?" The Journal of Taxation, February, 1996.

"Divided Tax Court Applies INDOPCO To Hostile Takeovers," The Journal of Taxation, January, 1996.

"State Seeks to Widen Tax Jurisdiction Over Out-of-State Companies," The Journal of Taxation, December, 1995. Company-Author: "Restrictive Proposed Regulations on Publicly Traded Partnerships Could Cause Any Partnership to be Taxed as a Corporation," (with Leslie H. Loffman, and Sanford C. Presant) The Tax Magazine, TAXES, September, 1995.

Author: "The Partnership Anti-Abuse Regs. Revisited: Is There Calm After the Storm?" The Journal of Taxation, August, 1995.

"Internal Revenue Service Improves Partnership Anti-Abuse Regs., but Major Problems Remain," The Journal of Taxation, March, 1995.

Proposed Regulations Address Relief for Real Estate Professionals Under the Passive Loss Rules," The Tax Magazine, TAXES, March, 1995. "Tax Consequences of Business and Investment-Driven Uses of Derivatives," The Tax Magazine, TAXES, December, 1994. "Internal Revenue Service Addresses Tax Treatment of Partnership Distributions of a Partner"s Debt or Stock," The Monthly Digest of Tax Articles, June, 1994.

"The Final Section 704 (c) Regulations: The Good and the Bad," Journal of Real Estate Taxation, Summer, 1994.

"Choice of Entity: How To Choose, How to Change," Taxes, June, 1994. "Controversial Partnership Anti-Abuse Propagation

Regs. Raise Many Questions," Journal of Taxation, August, 1994.

"Insolvent Partner Taxed on Partnership"s COD Income Despite Code Provision," Journal of Taxation, October, 1994. "Passive Loss Audit Guidelines Highlight Issues for Taxpayers," Taxes, October, 1994.

"Internal Revenue Service Challenges South Corporation Basis Increase for COD Income," Journal of Taxation, December, 1994. Company-Author: "Expenses Related to Failed Merger Defense Held to Be Deductible Despite INDOPCO," with Ryan Brenneman, Journal of Taxation, January, 1995.

Author: "Internal Revenue Service Improves Partnership Anti-Abuse Regs., But Major Problems Remain," Journal of Taxation, March, 1995.

"RRA "93 Liberalizes Passive Loss Restrictions for Real Estate Professions," 11 Journal of Partnership Taxation 15 (1994). "Further Developments Concerning Passive Losses," 72 Taxes 136 (1994). "How to Avoid Capital Loss Treatment on the Abandonment of a Partnership Interest," 80 Journal of Taxation 158 (1994).

"New Rules Address Capital Gains on Some Investments," 72 Taxes 51 (1994).

"Internal Revenue Service Issues New Regulations on Hedging Transactions," 72 Taxes 3 (1994). "1993 Tax Legislative Changes to the Passive Activity Loss Rules," 71 Taxes 611 (1993).

"Proposed 1398 Regs. Raise Conflict Between Debtors and Bankruptcy Trustees," 79 Journal of Taxation 12 (1993).

"UPREITs: Fad or Fixture?" 71 Taxes 395 (1993). "Final Regs. Simplify the Rules for Acquisitions of Debt by Related Parties," 78 Journal of Taxation 196 (1993).

"Internal Revenue Service Addresses Tax Treatment of Partnership Distributions of a Partner"s Debt or Stock," 71 Taxes 187 (1993). "Internal Revenue Service Issues Proposed Regulations on Debt Modifications," Taxes, February 1993.

"New Rulings on Purchase Price Reductions Do Not Provide Much Relief," The Journal of Taxation, February 1993.

"Internal Revenue Service Addresses Cancellation of Debt Income Under Partnership and Passive Activity Rules," The Journal of Taxation, January 1993. "Tax Planning Foreign NonCorporate Bankruptcies," Taxes, October 1992. "Internal Revenue Service Adopts Inconsistent Positions on Nonrecourse Debt," The Journal of Taxation, October 1992.

""Thumbs Up" for The Proposed Activity Regulations," Taxes, July, 1992.

"Planning for Non-corporate Debt Workouts Outside of Bankruptcy," Taxes, May 1992. "The Application of Section 469 To Real Estate Developers: The Search for a Solution to a Problem That Should Not Exist," Tax Notes, March 1992.

"Internal Revenue Service Attacks Hospital Joint Ventures," Taxes, February 1992. "The Tax Consequences to a Debtor from a Transfer of Its Indebtedness," TAXES - The Tax Magazine, December, 1991.

"The Single-Class-of-Stock Regulations, Round Two: The Internal Revenue Service Retreats," The Journal of Taxation, November, 1991.

"The Internal Revenue Service "Fixes" the Developer Rule," The Journal of Real Estate Taxation, Fall, 1991. "PALs at Four: Living with the Regulations," TAXES - The Tax Magazine, November, 1990. "Internal Revenue Service "Fixes" the Developer Rule," 19 Journal of Real Estate Taxation, 1991.

"Deferred Exchanges Easier Under Final Regs.," 47 Taxation for Accountants 76, 1991.

"Regs. Increase Gain Potential If Related Party Acquires Debt," 74 Journal of Taxation 354, 1991. "Section 1274 and COD Income Due to Modification of the Interest Rate in a Debt Instrument," 68 TAXES504-519, 1990.

"Internal Revenue Service Eases Passive Loss Limitation Foreign Casualty Losses," 68 TAXES363-367, 1990. "The Activity Regulations: Playing New Games with Building Blocks," 67 TAXES411-437.

"PALs at Three: What We Know, What We Don"t Know and What Went Wrong," 67 TAXES715-734, 1989.

"Corporate PALs: The Impact of the New Activity Regulations on C Corporations," 2 Corporate Taxation 11-19, 1989. "Changing PALs: Amendments To The First Secretariat of Passive Activity Loss Regulations," 67 TAXES502-511, 1989. "North American Palladium Ltd Material Participation Rules Harbor Unpleasant Surprises for Corporations," Volume 1, Number.

6, Corporate Taxation, 5-10, 1989.

"PALs at Two: What We Know and Don"t Know About Passive Activity Losses on Their Second Birthday," 66 TAXES833-850, 1988. "Notice 88-94: A Flexible Transnational Rule for the Definition of and Activity," 66 TAXES658-662, 1988.

"The Effect of Internal Revenue Service Notice 88-75 on PTPs," 40 Tax Notes 747-757, 1988. "More Fun and Games with PALs: The First set of Section 469 Regulations," 66 TAXES235-261, 1988.

"Publicly Traded Partnerships and the 1987 Acting," 38 Tax Notes 183-186, 1988.

"Passive Activity Loss Limitations Can Have Unexpected Impact on Corporations," 68 Journal of Taxation 20-29, 1988. "What We Do and Don"t Know About PALs," 37 Tax Notes 429-439, 1987. "Fun and Games with our New PALs," 64 TAXES801-813, 1986.

"Tax Court Explores The Boundaries Of Material Participation In Passive Activities," The Journal of Taxation, December, 1996.

"The Section 1001 Debt Modification Regulations: Problems and Opportunities," The Journal of Taxation, October, 1996. "Proposed Check-The-Box Business Classification Regulations Simplify Current Rules," Journal of Partnership Taxation, Fall, 1996.

"Partnership Deemed Terminations Will Be Simpler Under New Proposed Regulations," The Journal of Taxation, September, 1996. "Tax Administration in the 90s: An Agenda to Limit Legitimate Tax Planning Techniques," The Tax Magazine, TAXES, April, 1996.

"Divided Tax Court Allows Deduction of Interest on Tax Arising From a Trade or Business," The Journal of Taxation, April, 1996.

"Internal Revenue Service Issues Final Regulations on Passive Loss Relief for Real Estate Professionals," The Tax Magazine, TAXES, February, 1996. Company-author: "The Single-Class-of-Stock Rules, Round Three: The Final Regulations (with Michael Fondo)," The Journal of Taxation, September 1992. "Supreme Court Approves Focus on Long-Term Benefit in Takeover Expense Controversy," (with Lynn A. Schewe and Michael C. Fondo) The Journal of Taxation, June 1992.

"Campbell-is The Volcano Really Dormant Again?" (with Thomas M. Stephens) Journal of Taxation of Investments, March 1992.

(with Lynne A. Schewe) "New Propagation Regs. Limit Disguised Sales Through the Use of Partnerships," Corporate Taxation, September/October, 1991.

(with Thomas M. Stephens and Louis South. Freeman) "Regs. Increase Gain Potential If Related Party Acquired Debt," The Journal of Taxation, June, 1991.

(with Lynne A. Schewe and Louis South. Freeman) "How to Establish Deductions for Friendly Takeover Costs by Limiting National Starch," The Journal of Taxation, March, 1991.

(with David Evaul) Passive Activity Losses, (Little Brown 1995). "Final PTP Regs. Abandon Restrictive Conditions and Adopt Workable New Exemptions," with Leslie H. Loffman and Sanford C. Presant, The Journal of Taxation, May, 1996. Adjunct Professor of Taxation, Chicago-Kent College of Law, 1990-1992.

Lectures for 1993-1994: American Bar Association.

Southern Federal Tax Conference. ALI/American Bar Association.

New York University Real Estate Institute. Indiana Society of Certified Public Accountants"son

American Federal Tax Institute.

College of William & Mary. Heart of America Tax Institute. Chicago Federal Tax Forum.

University of Chicago Tax Conference.

Maryland Institute on Continuing Legal Education. Law Clerk to Judge Cynthia H. Hall, United States.

Tax Court, 1977-1979. Member: Chicago (Chair, 1991-1992.

Vice-chair, 1990-1991, Secretary, 1989-1990, Member, Executive Committee, 1983-1990, Chair, General Tax Division, 1983-1985, Federal Taxation Committee) and American (Section of Taxation: Vice Chair, 1993.

Council Director, 1990-1993, Chair, Task Force on Passive Activity Losses, 1986-1990, Chair, Committee on General Income Tax Problems, 1987-1989. Vice Regional Liaison, 1989-1990).

Achievements

Richard M. Lipton has been listed as a reputable lawyer by Marquis Who's Who.

Membership

Member: Chicago (Chair, 1991-1992. Vice-chair, 1990-1991, Secretary, 1989-1990, Member, Executive Committee, 1983-1990, Chair, General Tax Division, 1983-1985, Federal Taxation Committee) and American (Section of Taxation: Vice Chair, 1993. Council Director, 1990-1993, Chair, Task Force on Passive Activity Losses, 1986-1990, Chair, Committee on General Income Tax Problems, 1987-1989.

Vice Regional Liaison, 1989-1990).

Connections

Married Jane Brennan, May 24, 1981. Children: Thomas, Anne, Martin, Patricia.

Father:: Sanford Y. Lipton Goldman
Mother:: Sarah (Kentor) Goldman
Spouse:: Jane Brennan
child:: Anne Lipton
child:: Thomas Lipton
child:: Martin Lipton
child:: Patricia Lipton

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Richard M. Lipton

Background

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1977

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