| New TAM Highlights Issues in Like-Kind Exchanges Involving Intangibles |
The Tax Executive |
2006 |
| A Divided Tax Court Rejects a Regulation -- and Struggles with Administrative Law -- in Swallows Holding |
Journal of Taxation |
2006 |
| Will Black & Decker Turn Out to be a Pyrrhic Victory for the IRS? |
Journal of Taxation |
2006 |
| The ‘State of the Art’ in Like-Kind Exchanges, 2006 |
Journal of Taxation |
2006 |
| Misuse of Anti-Abuse |
Journal of Passthrough Entities |
2006 |
| What Will Be the Impact of the Government’s Economic Substance Victory in Coltec? |
Journal of Passthrough Entities |
2006 |
| ‘Securities’ and Like-Kind Exchanges |
Journal of Passthrough Entities |
2006 |
| At-Risk Rules and DROs: Did The Tax Court Err in Hubert Enterprises? |
Journal of Taxation |
2005 |
| Taxable Sale or Nontaxable Reorganization: The Tax Court Draws a Line in Tribune Company |
Journal of Taxation |
2005 |
| Code Sec. 6111 and the Partnership Tax Practitioner |
Journal of Passthrough Entities |
2005 |
| Broad Scope of Section 470 Catches Many Non-Abusive Transactions |
Journal of Taxation |
2005 |
| Dealing with the Service’s Interim Guidance on Downward Basis Adjustments under 734 and 743 |
Journal of Taxation |
2005 |
| New Tax Shelter Decisions Present Further Problems for the IRS |
Journal of Taxation |
2005 |
| The World Changes: Broad Sweep of New Tax Shelter Rules in AJCA and Circular 230 Affect Everyone |
Journal of Taxation |
2005 |
| Controversial Prop. Regs. on Disguised Sales of Partnership Interests — IRS Jumps into the Deep End |
Journal of Taxation |
2005 |
| Acquisitions, Dispositions & Structuring Techniques |
Journal of Passthrough Entities |
2005 |
| The Intersection of Delaware Statutory Trusts and Tenancies-In-Common |
Real Estate Taxation |
2005 |
| Lesson from Castle Harbour: The Service Loses a Significant Tax Shelter Case |
Journal of Taxation |
2005 |
| Reliance On Tax Opinions: The World Changes Due to Long Term Capital Holdings and the AJCA |
Journal of Taxation |
2004 |
| Tenancy-in-Common Interests: A Valuable Addition to the Financial Planner’s Toolkit |
Journal of Practical Estate Planning |
2004 |
| Foreign Inventory Transactions May Give Rise to a Reportable Transaction |
BNA International Inc. |
2004 |
| IRS Bars Taxpayers From Building Replacement Property On Their Own Land -- Or Does It? |
Journal of Taxation |
2004 |
| Delaware Statutory Trusts And 1031: A Marriage Made In Heaven Or Just A Pipe Dream? (with Todd Golub and Daniel F. Cullen) |
Journal of Taxation |
2004 |
| New Temp. Regs. On Allocation Of Foreign Tax Credits Present Planning Opportunities (with Todd Golub) |
Journal of Taxation |
2004 |
| IRS Ruling Creates Tax Controversy For Partnership Mergers |
Practical Tax Strategies |
2004 |
| Implications Of California Tough New Anti-Tax Shelter Rules |
Practical Lawyer |
2004 |
| ‘Tax Shelter’ And ‘Tax Shelter Opinion’ -- IRS, In Another Try At Circular 230, Strikes Out Again |
Journal of Taxation |
2004 |
| When Is A Partner Not A Partner? When Does A Partnership Exist? |
Journal of Taxation |
2004 |
| Rev. Rul. 2003-56: The More You Look, The Uglier It Gets |
Journal of Passthrough Entities |
2004 |
| Prop. Regs. On Withholding For Partnerships With Foreign Partners Would Ease Burdens |
Journal of Taxation |
2003 |
| IRS, In New Procedure, Eases The Rules To Allow REITS To Make Subordinated Loans |
Journal of Taxation |
2003 |
| Multi-Year Deferred Like-Kind Exchanges By Partnerships -- Is The New Rev. Rul. A Trojan Horse? |
Journal of Taxation |
2003 |
| Book, co-author (with David Evaul and Todd Wallace) |
Passive Activity Losses |
1995 |
