| TERMINATION FEES MAY BE DEDUCTIBLE |
Tax Notes |
2012 |
| ABSOLUTE POWER CORRUPTS ABSOLUTELY: BASIS OVERSTATEMENT AND THE SIX-YEAR LIMITATIONS PERIOD – SHOULD THE IRS BE ALLOWED TO RE-WRITE THE LAW RETROACTIVELY? |
Tax Management Memorandum |
2011 |
| GIFT CARD PROGRAMS – WILL THE IRS ALLOW INCOME DEFERRAL FOR GIFTCOS? |
Tax Notes |
2011 |
| MAYO FOUNDATION – THE SUPREME CLARIFIES THE STANDARD OF REVIEW FOR TAX REGULATIONS |
Latham & Watkins |
2011 |
| TO WHAT EXTENT CAN TREASURY ABANDON OR OVERRULE INDOPCO? |
Tax Notes |
2010 |
| GIFT CARD UPDATE - FEDERAL RESERVE BOARD ISSUES FINAL GIFT CARD REGULATIONS; IRS MAY PERMIT INCOME DEFERRAL FOR CERTAIN GIFTCOs |
Electronic Banking Law and Commerce Report |
2010 |
| TAX COURT INVALIDATES IRS REGULATIONS PURPORTING TO OVERRULE JUDICIAL PRECEDENT |
Latham & Watkins |
2010 |
| SEEKS TO OVERTURN COURT LOSSES THROUGH ISSUANCE OF RETROACTIVE REGULATIONS |
The Lawyer's Brief |
2009 |
| IRS’ ABILITY TO ASSESS TAX FURTHER RESTRICTED BY THE FEDERAL CIRCUIT’S DECISION IN SALMAN RANCH |
The Lawyer's Brief |
2009 |
| BAKERSFIELD: OVERSTATEMENT OF BASIS IS NOT “OMISSION OF GROSS INCOME” THAT TRIGGERS EXTENDED SIX-YEAR LIMITATIONS PERIOD FOR ASSESSING TAX |
The Lawyer's Brief |
2009 |
| TAX COURT PERMITS DEDUCTION OF TERMINATION FEE UNDER IRC SECTIONS 162 AND 165 |
Latham & Watkins |
2009 |
| EMERGING POST-INDOPCO ISSUES: RATIONALE AND STRATEGIES |
Practising Law Institute |
2009 |
| IRS TARGETS COLLEGES AND UNIVERSITIES IN NEW COMPLIANCE INITIATIVE |
Latham & Watkins |
2008 |
| TEXTRON AND WORKPAPER CONFIDENTIALITY |
Latham & Watkins |
2007 |
| D.C. TAX OFFICE EXPLAINS NOTICE ON RECALL AND REVIEW OF RULINGS |
State Tax Notes |
2002 |
| CALIFORNIA SUPREME COURT SURVEY - LANDGATE, INC. V. CALIFORNIA COASTAL COMM'N |
Pepperdine Law Review |
1999 |
