Crane v. Commissioner and its famous footnote 37 have inspired much controversy and commentary. This article discusses the issues and unresolved questions surrounding the calculation of gain from relief of nonrecourse indebtedness. It does so through a thorough analysis of the actions of the courts, the Congress, and administrative agencies. The author concludes by suggesting several possible courses of action in resolving remaining ambiguities.
Crane and Tufts: Resolved and Unresolved Issues,
12 Pepp. L. Rev.
Available at: http://digitalcommons.pepperdine.edu/plr/vol12/iss3/1