Taxation & Estate Planning

Keinan: Federal Taxation of Derivatives

Posted on April 30, 2008
Yoram Keinan (Michigan) has published United States Federal Taxation of Derivatives: One Way or Many?, 61 Tax Law. 81 (2007). Here is the Introduction: While derivatives have been utilized for almost a century, the use of derivatives has been exploding...

BB&T Fallout

Posted on April 30, 2008
Following up on yesterday's post on the Government's 4th Circuit victory in the BB&T LILO tax shelter case: BB&T Loses Tax Shelter Case in Second IRS Victory This Month (Bloomberg), by Ryan J. Donmoyer Wachovia Corp Sees 2Q Charge $800...

Tax Court Denies $1.34m Loss Deduction on WorldCom Stock

Posted on April 30, 2008
The Tax Court yesterday denied a former employee of WorldCom a $1.34 million loss deduction on WorldCom stock. Taghadoss v. Commissioner, T.C. Summ. Op. 2008-44 (4/29/08): Petitioner was employed by the WorldCom for 17 years. During the course of petitioner's...

Structuring a Tax Policy Workshop Series -- Columbia

Posted on April 30, 2008
Alex Raskolnikov, host of Columbia's Tax Policy Colloquium Series, continues our series on how to best structure a tax policy workshop series: We've just started a tax policy colloquium at Columbia, so our experience is limited to one year. Both...

To access this complete feed in the blog feed reader login or register for free.

Tax Court Denies Attorney's Deduction for Cell Phone Expenses

Posted on April 30, 2008
The Tax Court yesterday denied a deduction for various business expenses claimed by an Illinois real estate attorney, including cell phone expenses. Tash v. Commissioner, T.C. Memo. 2008-120 (4/29/08): The record did not indicate whether petitioner used his cellular telephone...

Authentic Happiness and Meaning at Law Firms

Posted on April 29, 2008
Peter H. Huang (Temple) & Rick Swedloff (Temple) have posted Authentic Happiness and Meaning at Law Firms, 58 Syr. L. Rev. ___ (2008), on SSRN. Here is the abstract: We advocate that law firms can and should foster authentic happiness...

Structuring a Tax Policy Workshop Series -- NYU (Student Perspective)

Posted on April 29, 2008
Dave Rifkin (Attorney-Advisor to Tax Court Judge Juan F. Vasquez; Adjunct Professor, Georgetown), a former student participant in NYU's Colloquium Series on Tax Law and Public Finance, continues our series on how to best structure a tax policy workshop series:...

4th Circuit Affirms Government's Victory in BB&T Corp. LILO Tax Shelter Case

Posted on April 29, 2008
On the heels of the Government's big win last week in the Fifth Third Bancorp LILO tax shelter case: the 4th Circuit today affirmed the Government's victory in the first LILO tax shelter case, BB&T Corp. v. United States, No....

Shores: Textualism and Intentionalism in Tax Litigation

Posted on April 29, 2008
David F. Shores (Wake Forest) has published Textualism and Intentionalism in Tax Litigation, 61 Tax Law. 53 (2007). Here is the Introduction: Tax cases frequently turn on issues of statutory construction. The statute might be general in nature, such as...

Ring: What's at Stake in the Sovereignty Debate?: International Tax and the Nation-State

Posted on April 29, 2008
Diane M. Ring (Boston College) has posted What's at Stake in the Sovereignty Debate?: International Tax and the Nation-State, 49 Va. J. Int'l L. ___ (2008), on SSRN. Here is the abstract: The international tax problems of today are typically...

How Americans View Charities: A Report on Charitable Confidence, 2008

Posted on April 29, 2008
The Brookings Institution has published How Americans View Charities: A Report on Charitable Confidence, 2008, by Paul C. Light. From the Executive Summary: [P]ublic confidence in charities remains at contemporary lows. ... The percentage of Americans who said they had...

Birthday Gift Suggestion

Posted on April 29, 2008
For those men approaching forty (or any other birthday): a birthday gift suggestion for your spouse. (Hat Tip: Dan Filler.)

Structuring a Tax Policy Workshop Series -- NYU (Co-Convenor's Perspective)

Posted on April 29, 2008
Daniel N. Shaviro, co-convenor of NYU's Colloquium Series on Tax Law and Public Finance, continues our series on how to best structure a tax policy workshop series: NYU had the first tax policy colloquium, for which I must thank John...

Beale: Tax Patents: At the Crossroads of Tax and Patent Law

Posted on April 29, 2008
Linda M. Beale (Wayne State) has posted Tax Patents: At the Crossroads of Tax and Patent Law, 2008 U. Ill. J.L. Tech. & Pol'y ___, on SSRN. Here is the abstract: Since the 1998 State Street case, the U.S. Patent...

Hellerstein: Is "Internal Consistency" Dead?: Reflections on an Evolving Commerce Clause Restraint on State Taxation

Posted on April 29, 2008
Walter Hellerstein (Georgia) has published Is "Internal Consistency" Dead?: Reflections on an Evolving Commerce Clause Restraint on State Taxation, 61 Tax L. Rev. 1 (2007). Here is the abstract: Under the internal consistency doctrine articulated by the U...

TIGTA: Audit Rate of Largest Corporations Down 20%

Posted on April 29, 2008
The Treasury Inspector General for Tax Administration yesterday released an audit report, Trends in Compliance Activities Through Fiscal Year 2007 (2008-30-095), which found: Enforcement revenue collected increased to $59.2 billion Total dollar amount of uncollected tax liabilities increased to $290...

McLure: Uniformity and Diversity in State Corporate Income Taxes

Posted on April 28, 2008
Charles E. McLure Jr. (Stanford University, Hoover Institution) has published Understanding Uniformity and Diversity in State Corporate Income Taxes, 61 Nat'l Tax J. 141 (2008). Here is the abstract: This article describes generic forces creating uniformity and diversity in state...

TaxProf Blog Weekend Roundup

Posted on April 28, 2008
Saturday: Tax Problems Threaten Al Franken's Senate Candidacy Structuring a Tax Policy Workshop Series -- Boston College Government Victories Using the Economic Substance Doctrine Ex-Dividend Day Price and Volume: The Case of 2003 Dividend Tax Cut Sunday: Top 5 Tax...

Smith: The Deliberative Stylings of Leading Tax Law Scholars

Posted on April 28, 2008
Andre L. Smith (Florida International) has published The Deliberative Stylings of Leading Tax Law Scholars, 61 Tax Law. 1 (2007). Here is the Introduction: This Article examines the deliberative techniques of leading tax scholars as gleaned from articles they have...

Schneider: Use of Judicial Doctrines in Federal Tax Cases Decided by Trial Courts, 1993-2006: A Quantitative Assessment

Posted on April 28, 2008
Daniel M. Schneider (Northern Illinois) has posted Use of Judicial Doctrines in Federal Tax Cases Decided by Trial Courts, 1993-2006: A Quantitative Assessment on SSRN. Here is the abstract: This paper examines the use of judicial doctrines in federal tax...

Structuring a Tax Policy Workshop Series -- Toronto

Posted on April 28, 2008
Ben Alarie and David Duff, co-hosts of the James Hausman Tax Law and Policy Workshop Series at the University of Toronto, continue our series on how to best structure a tax policy workshop series: The James Hausman Tax Law and...

Leviner Presents A New Era of Tax Enforcement - From "Big Stick" to Responsive Regulation Today at Bar Ilan University

Posted on April 28, 2008
Sagit Leviner (Bar-Ilan University, Israel) presents A New Era of Tax Enforcement - From "Big Stick" to Responsive Regulation at Bar Ilan University in Israel today as part of its Faculty Workshop Series. Here is the abstract: Recent developments in....

More Celebrity Tax Troubles: Britney Spears

Posted on April 28, 2008
Like Al Franken, Britney Spears has run afoul of California tax authorities, who have slapped a $24,000 tax lien on one of her myriad companies, Britney On Line Inc.: Access Hollywood Don't Mess With Taxes E! Online

Doonesbury on Laptops in the Classroom

Posted on April 28, 2008
Check out the hilarious Doonesbury from Sunday's newspaper on laptops in the classroom. Here is the last panel:

Rising Taxes, Not Rising Mortgage Payments, Primary Cause of Middle-Class Squeeze

Posted on April 28, 2008
I previously blogged (here and here) Todd Zywicki's contention that in their book, The Two-Income Trap: Why Middle Class Mothers and Fathers are Going Broke, Elizabeth Warren and her daughter Amelia Warren Tyagi wrongly blamed rising mortgage and health care...

Structuring a Tax Policy Workshop Series -- Loyola-L.A.

Posted on April 28, 2008
Ellen Aprill, Jenny Kowal, Katie Pratt, and Ted Seto, co-hosts of Loyola-L.A.'s Tax Policy Colloquium Series, continue our series on how to best structure a tax policy workshop series: We all suggest Colloquium speakers, participate in the weekly Colloquium discussions,...

Hickman: Responding to Treasury's (Lack of) Compliance with APA Rulemaking Requirements

Posted on April 28, 2008
Kristin E. Hickman (Minnesota) has posted A Problem of Remedy: Responding to Treasury's (Lack of) Compliance with Administrative Procedure Act Rulemaking Requirements, 76 Geo. Wash. L. Rev. ___ (2008), on SSRN. Here is the abstract: In earlier work, I found...

Heriot: The ABA's "Diversity" Diktat

Posted on April 28, 2008
The ABA's "Diversity" Diktat (Wall Street Journal), by Gail Heriot (San Diego): If you have ever wondered why colleges and universities seem to march in lockstep on controversial issues like affirmative action, here is one reason: Overly politicized accrediting agencies...

Feldstein: Effects of Taxes on Economic Behavior

Posted on April 27, 2008
Martin Feldstein (Harvard University, Deparment of Economics; NBER) has published Effects of Taxes on Economic Behavior, 61 Nat'l Tax J. 131 (2008). Here is the abstract: This paper discusses how the effects of taxes on economic behavior are important for...

Using Insurance Law and Policy to Interpret §§ 165 & 213

Posted on April 27, 2008
Andrew Blair-Stanek (J.D. 2008, Yale) has published Note, Using Insurance Law and Policy to Interpret the Tax Code's Loss and Medical Expense Provisions, 26 Yale L. & Pol'y Rev. 309 (2007). Here is the Conclusion: Insurance law and policy have...

Bloggers, promote your law blog by nominating your blog for inclusion in USLaw.com's Law Blog Directory and RSS Reader. Benefits described.