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I. INTRODUCTION 427 II. OVERYIEW OF NONRECOGNITION RULES 431 A. General Nonrecognition Rules 431 1. Like Kind Exchanges 431 2. Involuntary Conversions 432 3. Wash Sales 433 B. Nonrecognition Rules [...], Nonrecognition rules are a prominent feature of the income tax laws and are a source of considerable complexity and tax planning. Included among the nonrecognition rules contained in the Internal Revenue Code are provisions applying to like kind exchanges, corporate formations, corporate reorganizations, parent-subsidiary liquidations, and partnership formations and distributions. The policies that arguably support the nonrecognition rules include the familiar trio of tax policy concerns--efficiency, equity, and tax administration. None of these policies, however, provide a strong basis for most of the nonrecognition rules as currently formulated. The efficiency case generally lacks evidentiary support. The equity case is complicated by the fact that the rules operate in a second-best world where the tax base deviates from economic income. And the tax administration argument for the rules, while plausible in theory, is compromised because nonrecognition frequently occurs where there are no valuation and liquidity concerns as a result of the receipt of publicly traded property or the presence of related cash sales. This Article generally dispenses with the efficiency and equity bases for the nonrecognition rules because of the aforementioned flaws. As a result, the similar replacement property factor, which is a product of these rationales for nonrecognition and currently is prominent in most nonrecognition provisions, should be generally discarded. This Article proposes a standard for designing nonrecognition rules that generally ignores the similarities or differences in the relinquished and replacement properties, unless the properties are either identical or possess a very high degree of similarity, and instead takes into account the following: presence of difficult-to-value property, presence of illiquid property, use of rules that are narrowly tailored to common transactional forms that are typically selected for significant non-tax reasons, and adherence to certain corporate tax policies. This Article then applies this standard as a basis for suggesting revisions to the current nonrecognition rules. Included among the recommended reforms are (1) eliminating nonrecognition for like kind exchanges; (2) eliminating the control requirement for shareholders to receive nonrecognition upon transfers to corporations, but generally taxing shareholders on the transfer or receipt of publicly traded property; and (3) permitting nonrecognition in corporate reorganizations irrespective of satisfying continuity of interest or continuity of business enterprise requirements, but taxing shareholders on the receipt of publicly traded stock. Overall, the recommended approach and reforms should serve to rationalize and simplify the non-recognition rules contained in the Internal Revenue Code.

From the onset of the pandemic in the United States, racial disparities in COVID-19 outcomes have been evident. In April 2020, several events prompted a concerned group of colleagues to form the Black Equity Coalition (BEC), a Black-led coalition in Allegheny County, Pennsylvania, which brings together professionals from multiple sectors who aim to ensure an equitable response to the COVID-19 pandemic. Several significant milestones have been achieved, and this article describes the development, functioning, and outcomes of the Coalition in the first 15 months of operation (April 2020–June 2021). COVID-19 was the reason for such an unprecedented effort, but this BEC infrastructure will be needed long after COVID-19 is controlled. In addition to short-term activities and reactive measures to prevent and mitigate COVID-19 in Black populations, the BEC is serving as a crucial link between government, health care stakeholders, and communities to produce long-term systemic change. [ABSTRACT FROM AUTHOR]

Activities that show students a practical use for chemistry using common items such as food products, pharmaceuticals, and household products as sources of chemical compounds are presented. The importance of having adequate resource materials available for students is emphasized. (KR)

I. INTRODUCTION In several respects, the U.S. tax system strives for neutral taxation. Neutrality is often concerned with similarly taxing different types of income that are economically equivalent. (1) For [...]