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