With the increased frequency of mergers and acquisitions in the 1980s, Congress became concerned about abusively large payments made to executives when a corporation was acquired. In response to this perceived abuse, Congress enacted a pair of tax statutes designed to reduce or eliminate these payments. Sections 280G and 4999 of the Internal Revenue Code, both entitled “Golden parachute payments,” are punitive tax provisions designed to discourage corporations from making, and executives from receiving, abusively large payments when a corporation is acquired.