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EXHIBIT A: BACKGROUND PAPER ON THE CANADIAN TAXATION OF GAINS AT DEATH.

• Authors : Zelenak, Lawrence A.¹

• Source: Tax Lawyer. Fall2004, Vol. 58 Issue 1, p313-318. 7p.

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The Royalties Exception to Unrelated Business Income: Sierra Club v. Commissioner.

• Authors : Holbrook, Richard

• Source: Tax Lawyer. Winter96, Vol. 49 Issue 2, p517. 16p.

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TAX ANALYSIS OF RESEARCH AND DEVELOPMENT COST-SHARING ARRANGEMENTS.

• Authors : Augustyn, Francene M.

• Source: Tax Lawyer. Summer89, Vol. 42 Issue 4, p961. 37p.

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EVALUATION OF THE PROPOSED MODEL COMPREHENSIVE INCOME TAX.

• Source: Tax Lawyer. Spring79, Vol. 32 Issue 3, p563. 124p. 4 Charts.

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REPORT OF THE COMMITTEE ON SMALL TAXPAYER PROGRAM.

• Authors : Fisher, Richard A.

• Source: Tax Lawyer. Summer81, Vol. 34 Issue 4, p931. 2p.

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STATE INCOME TAXATION OF NONRESIDENT PROFESSIONAL ATHLETES.

• Authors : Krasney, Jeffrey K.

• Source: Tax Lawyer. Winter94, Vol. 47 Issue 2, p395. 30p.

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A CASE OF MISTAKEN IDENTIFICATION: WHEN INCOME IS EARNED AND THE CLASSIFICATION OF EARNINGS AS...

• Authors : Bozajian, Gina L.

• Source: Tax Lawyer. Winter93, Vol. 46 Issue 2, p583. 11p.

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Property Purchase or Payment in Kind? The Oxford Paper Conundrum.

• Authors : Scarborough, Robert H.¹

• Source: Tax Lawyer. Spring2009, Vol. 62 Issue 3, p823-865. 43p.

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SENATE SUBCOMMITTEE INVITES IDEAS ON TAX CHANGES NEEDED FOR ELDERLY.

• Source: Tax Lawyer. Apr66, Vol. 19 Issue 3, p81. 1p.

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The Proper Tax Treatment of the Transfer of a Compensatory Partnership Interest.

• Authors : Kahn, Douglas A.

• Source: Tax Lawyer. Fall2008, Vol. 62 Issue 1, p1-58. 58p.

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