About the authors: Charles Davenport received his J.D. from Harvard University. He has practiced law in San Francisco, worked in the Office of Tax Legislative Counsel at the Department of Treasury, been Assistant Director of the Congressional Budget Office, and taught at the University of California, Davis, and at Rutgers University. He is the author of several books, and contributes frequently to Tax Notes, where he is a Contributing Editor. W. Eugene Seago is the R. B. Pamplin Professor of Accounting at Virginia Polytechnic Institute and State University. He received his PhD and J.D. from the University of Georgia. He is a Certified Public Accountant, a member of the Virginia bar, and a member of the America Bar Association Section on Taxation. He is the author of numerous articles on tax accounting, and a contributing author to West’s Federal Income Taxation. He has written the “Current Development in Tax Accounting” section of The Tax Lawyer for the past twelve years.