Deconstructing Code Sec. 1032 : An Analysis and Commentary

In a response to Professor Alvin C. Warren's article, quot;Taxation of Options on the Issuer's Stockquot; (TAXES, March 2003 at 39), the author explores Code Sec. 1032 as it applies to modern-day transactions. First, he applies a detailed overview of Code Sec. 1032 and the uncertain application of its provision to various transactions, including derivative transactions on issuer's own stock. The author then outlines alternative ways of revising Code Sec. 1032 to ensure its proper application, including a comparison of a narrow-based application of Code Sec. 1032 and a broad-based application