TaxProf Blog

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Pepperdine University School of Law

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Monday, October 15, 2012

The Tax Lawyer Publishes New Issue

Tax Lawyer The Tax Lawyer has published Vol. 65, No. 3 (Spring 2012):

October 15, 2012 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, October 13, 2012

ABA Tax Section Seeks Nominations for Janet R. Spragens Pro Bono Award

ABA Tax Section The ABA Tax Section is soliciting nominations for the 2013 Janet Spragens Pro Bono Award. This award was established in 2002 to recognize one or more individuals or law firms for outstanding and sustained achievements in pro bono activities in the tax law. In 2007 the award was renamed in honor of the late Janet R. Spragens, who received the award in 2006 in recognition of her dedication to the development of low income taxpayer clinics throughout the United States. The selection criteria are here. Please submit nominations to Laura Newland by October 29, 2012.

October 13, 2012 in ABA Tax Section, Legal Education, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, October 5, 2012

ABA Tax Section Publishes Summer 2012 Issue of News Quarterly

ABA NQThe ABA Tax Section has published 31 News Quarterly No. 4 (Summer 2012):

October 5, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, September 15, 2012

ABA Tax Section Fall Meeting

ABA Tax SectionThe ABA Tax Section fall meeting concludes today in Boston. The full program is here. Tax Profs with speaking roles today include:

  • Civil & Criminal Tax Penalties: Flaws in the Façade: The Anti-Injunction Act After NFIB v. Sibelius and Cohen v. United States -- Steve Johnson (Florida State)
  • Pro Bono & Tax Clinics: Decisions and Rulings Impacting Low Income Taxpayers -- Keith Fogg (Villanova), Diana Leyden (Connecticut)
  • Sales, Exchanges & Basis: Current Non-Section 1031 Developments -- Erik M. Jensen (Case Western)
  • Sales, Exchanges & Basis: Is It Treated as a Sale? Something Else? – Part III: Issues Surrounding Tax Ownership of US Residential Mortgage Debt -- Bradley T. Borden (Brooklyn)
  • Sales, Exchanges & Basis: Professor Jensen Speaks His Mind on the Supreme Court’s Decision in National Federation -- Erik M. Jensen (Case Western)

September 15, 2012 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, September 14, 2012

ABA Tax Section Fall Meeting

ABA Tax SectionThe ABA Tax Section fall meeting continues today in Boston. The full program is here. Today's highlight is the Teaching Taxation program on Taxing Homeownership (Including Imputed Income): A Debate:

This program will consist of a Lincoln-Douglas-style debate between two opposing teams on the question of whether the tax incentives for homeownership should be repealed. The teams will focus on the taxation of imputed income from homeownership as well as the home mortgage interest deduction, the deduction for real property taxes, and section 121. Each side will have the opportunity to present its case and question the opposition. The audience will also be provided an opportunity to submit questions and to vote on a winner at the end of the debate.

  • Adam Chodorow (Arizona State) (Chair)
  • Anthony Infanti (Pittsburgh) (Moderator)
  • Neil Buchanan (George Washington)
  • Steve Johnson (Florida State)
  • Lily Kahng (Seattle)
  • Dennis Ventry Jr. (UC-Davis)

For more on the panel, see Neil Buchanan, Debating Housing Subsidies in the Tax Code -- Against Myself.

Other Tax Profs with speaking roles today include:

  • Exempt Organizations:  Election Year Issues for Exempt Organizations -- Ellen Aprill (Loyola-L.A.)
  • Individual & Family Taxation:  A Disabled Client and the Tax Code – Some Gems. What Every Tax Practitioner and Controversy Attorney Should Know In Order to Properly Represent Their Clients -- Keith Fogg (Villanova), David Rice (California Polytechnic State University)
  • Partnerships & LLCs:  Our Little Tea Party: Tax Reform and Its Legislative Outlook -- Stephen Shay (Harvard)
  • Publications:  Alice Abreu (Temple)
  • Tax Policy & Simplification:  Tax Platforms of the Presidential Candidates: Does it Make a Difference to Voters? -- Roberta Mann (Oregon), Andrea Louise Campbell (MIT), David Gamage (UC-Berkeley), Darien Shanske (UC-Hastings)
  • Tax Practice Management and Estate & Gift Taxes:  Paralegals: Everything You Need to Know About Using Them in Your Practice -- Michael Lang (Chapman)

September 14, 2012 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, September 13, 2012

ABA Tax Section Fall Meeting

ABA Tax SectionThe ABA Tax Section fall meeting kicks off today in Boston. The full program is here

September 13, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, August 27, 2012

Legal Aid Society Seeks to Sponsor ABA Tax Section Public Service Fellow

ABA Tax Section From the Legal Aid Society of New York:

The Legal Aid Society is interested in sponsoring an applicant for the ABA Section of Taxation Public Service Fellowship. The fellow would work with our Low-Income Taxpayer Clinic (LITC) to advocate for low-income taxpayers before the IRS and New York State Department of Taxation and Finance with respect to income tax issues, including but not limited to issues arising in connection with the Affordable Care Act health insurance premium and credit, other refundable credits, collection alternatives, misclassified employees, innocent spouse relief, and identity theft. Individuals who will receive their J.D. or L.L.M. in 2013, or recent graduates with experience in tax law are encouraged to apply. The Legal Aid Society’s LITC has provided assistance to thousands of low-income taxpayers since 2001 and works with other advocates in The Legal Aid Society and throughout New York City to address tax issues which affect low income New Yorkers. ...

Application by email is required and ... must be submitted by September 10, 2012. ... Email a resume and cover letter, fellowship proposal, law school transcript, list of references and writing sample. ... In the subject line of the email, please write “Tax Fellowship”.

August 27, 2012 in ABA Tax Section, Tax, Tax Prof Jobs | Permalink | Comments (1) | TrackBack (0)

Tuesday, August 14, 2012

The Tax Lawyer Publishes New Issue

Tax Lawyer The Tax Lawyer has published Vol. 65, No. 2 (Winter 2012):

August 14, 2012 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, July 26, 2012

ABA Tax Section Seeks to Hire Pro Bono Staff Counsel

ABA Tax Section Logo (2012)The ABA Tax Section is seeking to fill the position of Pro Bono Staff Counsel:

Hiring range: $68,900- $76,900

Manages and oversees pro bono projects of the Section of Taxation which includes Adopt-a-Base Military VITA (Volunteer Income Taxpayer Assistance), Calendar Call program with the U.S. Tax Court and other outreach programs to low income taxpayers. Also acts as staff liaison to Committee on Low Income Taxpayers and Pro Bono. Includes legal writing, research, public policy development and public speaking.

Education:  Doctoral Degree (JD, PhD)

Experience:  JD and admission to the bar in at least one jurisdiction. At least 4 years working in relevant specialized area of law. High level of skills at legal writing and research, oral and written communications, and organizational skill. Substantial experience in policy analysis.

July 26, 2012 in ABA Tax Section, Tax, Tax Prof Jobs | Permalink | Comments (2) | TrackBack (0)

Monday, July 16, 2012

Fall 2012 Law Review Article Submission Guide

Nancy Levit (UMKC) & Allen Rostron (UMKC) have updated their incredibly useful document, which contains two charts for the Fall 2012 submission season covering 202 law reviews.

The first chart (pp. 1-52) contains information gathered from the journals’ websites on:

  • Methods for submitting an article (such as by e-mail, ExpressO, or regular mail)
  • Any special formatting requirements
  • How to request an expedited review
  • How to withdraw an article after it has been accepted for publication elsewhere

The second chart (pp. 53-59) contains the ranking of the law reviews and their schools under six measures:

  • U.S. News: Overall Rank
  • U.S. News: Peer Reputation Rating
  • U.S. News: Judge/Lawyer Reputation Rating
  • Washington & Lee Citation Ranking
  • Washington & Lee Impact Factor
  • Washington & Lee Combined Rating

They also have posted a list of links to the submissions information on each law journal’s website.

July 16, 2012 in ABA Tax Section, Law School Rankings, Legal Education, Scholarship | Permalink | Comments (0) | TrackBack (0)

Wednesday, June 20, 2012

The Tax Lawyer Publishes New Issue

Tax Lawyer The Tax Lawyer has published Vol. 65, No. 1 (Fall 2011):

June 20, 2012 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, June 15, 2012

2012 Tannenwald Tax Writing Competition

Tannenwald Writing Competition_Page_1

For students who wrote tax seminar papers last semester:  the Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship and American College of Tax Counsel are sponsoring the 2012 Tannenwald Writing Competition:

Named for the late Tax Court Judge Theodore Tannenwald, Jr., and designed to perpetuate his dedication to legal scholarship of the highest quality, the Tannenwald Writing Competition is open to all full- or part-time law school students, undergraduate or graduate. Papers on any federal or state tax-related topic may be submitted in accordance with the Competition Rules.

Prizes:

  • 1st Place:  $5,000, free trip to the 2013 ABA Tax Section Mid-Year Meeting in Orlando, and publication in the Florida Tax Review
  • 2nd Place:  $2,500
  • 3rd Place:  $1,500

Deadline:  9:00 p.m. EST, July 3, 2012. Mail papers to: Tannenwald Foundation, Ste. 200, 1275 Pennsylvania Ave., N.W., Washington, D.C. 20004, Attn: Melnie Moore.

For more information, contact Nancy Abramowitz.

For a list of participating law schools, see here. For a list of winners from prior years, and their tax faculty sponsors, see here.

June 15, 2012 in ABA Tax Section, Law School Rankings, Scholarship, Tax, Teaching | Permalink | Comments (0) | TrackBack (0)

Wednesday, June 13, 2012

Call for Papers: The Tax Lawyer -- The State & Local Tax Edition

The Tax LawyerFrom Brandee Tilman, Editor-in-Chief of the State and Local Tax edition of The Tax Lawyer (via Alice Abreu (Temple), incoming Vice Chair, Publication, for the ABA Tax Section):

We are pleased to announce a call for articles for the Summer 2013 Edition of the ABA's The Tax Lawyer - The State and Local Tax Edition (SALTE). The SALTE features legal scholarship devoted to state and local taxation and is distributed to the nearly 18,000 members of the ABA Tax Section as well as other subscribers. Though not limited to academic and/or tax policy articles, this publication provides an excellent venue for these types of articles, while simultaneously providing authors with a wide readership of state and local tax professionals.  

Articles submitted for publication should be at least 40 double-spaced pages (or 10,000 words) plus footnotes, and should be submitted no later than November 15, 2012. The SALTE is a peer-reviewed publication, and publication decisions will be made by the Editor-in-Chief and Managing Editor, both of whom are practicing tax lawyers.  Offers of publication will be issued within 30 days of  receipt of the submission.

To submit an article or if you have any questions or concerns, please email Brandee A. Tilman, Editor-in-Chief (effective 7/1/12), or Jeffrey Reed, Managing Editor (effective 7/1/12).

June 13, 2012 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, June 11, 2012

ABA Tax Section Accepting Nominations for 2013-2015 Public Service Fellowships

ABA Tax Section The ABA Tax Section is accepting applications for Public Service Fellowships for 2013-2015:

Applications must be received by November 1, 2012 to be considered. Applicants selected for interviews will be invited to attend the Section’s meeting in on January 24-26, 2013, and asked to participate in interviews on January 26, 2013. ...

The Section will award up to two Fellowships for 2013-2015 to recent law school graduates or judicial clerks. Both LLM and JD candidates are eligible to apply. The proposed employment must involve taxation or administration of tax law and must be with a public-interest, non-profit section 501(c)(3) organization (the “Sponsoring Organization”). Each Fellow is expected to serve a two-year term with the Sponsoring Organization. The applicant must identify and secure a position with a Sponsoring Organization before applying for the Fellowship (although the position may be contingent upon award of the Fellowship). The application must be accompanied by a commitment letter from the Sponsoring Organization that describes the proposed employment with the Sponsoring Organization and explains why the Sponsoring Organization considers the applicant to be qualified to perform the work. The Sponsoring Organization must agree to hire the applicant, if the Fellowship is granted, and to fulfill all tax and other reporting obligations with respect to the amounts paid to the Fellow. The Sponsoring Organization must also describe how the applicant will be supervised. The Section does not expect to select an applicant unless the Sponsoring Organization has identified at least one attorney who will supervise the Fellow throughout the two-year period.

The Section provides an unrestricted grant to each Sponsoring Organization equal to the Fellow’s salary, payroll taxes, and benefits, which are formulated to be commensurate with judicial clerkship salaries. In addition, the Section will provide assistance with educational loans for those Fellows who are not covered by a law school low-income-protection plan. The amount of educational loan assistance a Fellow can expect will depend on the amount of debt, the type of loans, and whether the Fellow is eligible for assistance from any other loan-repayment or loan-assistance program. In general, the Section’s objective will be to provide funding sufficient to cover the interest accrued on the applicant’s educational loans during the two-year Fellowship period. The actual amount of the assistance provided will be determined on a case-by-case basis and may be subject to an overall limitation to be determined by the Section, in its sole discretion.

The Section will provide each Fellow with access to one or more mentors from the Section’s membership. The Section expects Fellows to join the Section and participate in Section activities during the Fellowship period. The Section will pay for, or waive, the Fellow’s ABA and Section dues for the duration of the Fellowship. Each Fellow will be expected to attend at least two of the three Section meetings per year. The Section will pay travel and meeting expenses associated with each meeting in accordance with ABA and Section reimbursement policies. The Fellows are encouraged strongly to participate in the activities of the Section’s public service oriented committees, such as the Pro Bono Committee and the Low Income Taxpayers Committee.

June 11, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, June 4, 2012

ABA Tax Section Publishes Spring 2012 Issue of News Quarterly

ABA NQ CoverThe ABA Tax Section has published 31 News Quarterly No. 3 (Spring 2012):

June 4, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, May 12, 2012

ABA Tax Section May Meeting

ABA Tax SectionThe ABA Tax Section May meeting concludes today in Washington, D.C. The full program here. Today's highlight is the presentation of the 2012 Distinguished Service Award to Phillip Mann (Miller & Chevalier, Washington, D.C.):

Mann is a former Chair of the ABA Tax Section. ... Under the administrations of Presidents Nixon and Ford, Mann served at the Treasury Department as Deputy Tax Legislative Counsel and Tax Legislative Counsel. ... A graduate of the University of Texas, Mann received both his B.B.A. and LL.B in 1962.

Tax Profs with speaking roles today include:

  • Pro Bono: Update On Pro Bono Matters -- Cynthia Lepow (Loyola-New Orleans), Francine J. Lipman (UNLV)
  • Sales, Exchanges & Basis: Is It Treated as a Sale? Lease? Financing? -- Bradley Borden (Brooklyn)
  • Section Program: Eliminating Tax Debt Through Offer in Compromise or Bankruptcy -- Keith Fogg (Villanova), Willard Timm (Georgia State)
  • Tax Practice Management: Avoiding Malpractice -- Michael Lang (Chapman)

May 12, 2012 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, May 11, 2012

ABA Tax Section May Meeting

ABA Tax SectionThe ABA Tax Section May meeting continues today in Washington, D.C.. The full program here. Today's highlight is the Teaching Taxation program on Thinking Outside the Box, While Inside a Tank:

This program will examine how think tanks and advocacy groups influence tax policy. The panelists will discuss the ways in which their respective organizations select research topics and causes, obtain financial support to achieve their objectives, interact with members of Congress and measure their success in influencing the tax legislative process. The panelists will also address how their organizations work with academics and others from educational institutions and experts from other outside groups.

  • Brian Galle (Boston College) (moderator)
  • J.D. Foster (Heritage Foundation)
  • Diane Lim Rogers (Concord Coalition)
  • Donald Marron (Urban Institute)

Other Tax Profs with speaking roles today include:

  • Bankruptcy & Workouts: Acquisition of Troubled Corporations -- Don Leatherman (Tennessee)
  • Diversity: The Road Less Traveled: Exploring Niche Tax Practices -- Janet Milne (Vermont)
  • Employee Benefits Distributions Update -- Kathryn Kennedy (John Marshall)
  • Indian Tribal Tax: States vs. Tribes: The Tobacco Tax Controversies -- Richard Pomp (Connecticut)
  • Partnerships & LLCs: Is there Alchemy when Debt Disappears in Partnership Contribution/Distribution Transactions? -- Don Leatherman (Tennessee)
  • Task Force on Patenting Tax Strategies -- Ellen Aprill (Loyola-L.A.)
  • Tax Policy and Simplification: Perspectives on Tax Reform: Restoring the Middle Class -- Roberta Mann (Oregon), Ajay Mehrotra (Indiana)

May 11, 2012 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, May 10, 2012

ABA Tax Section May Meeting

ABA Tax SectionThe ABA Tax Section May meeting kicks off today in Washington, D.C. The full program here. Today's highlight is the annual Woodworth Memorial Lecture by Heather Maloy (Commissioner, IRS Large Business & International Division), Where the Rubber Meets the Road – A View of the Tax System from a Tax Administrator’s Perspective.  Tax Profs with speaking roles today include:

  • The Bridge to Practice: Deciphering the US Supreme Court’s Tax Jurisprudence -- Linda Beale (Wayne State)
  • The Bridge to Practice: How to Become a Tax Rock Star: What You Must Know About Tax Law Practice -- Keith Blair (District of Columbia)
  • Low Income Taxpayers Representation Workshop: Timely Administrative Refunds -- Robert Nassau (Syracuse)
  • Low Income Taxpayers Representation Workshop: Timely Assessments -- Leslie Book (Villanova), Shelley Coe (American)
  • Low Income Taxpayers Representation Workshop: Timely Collection Action -- Keith Fogg (Villanova)
  • Low Income Taxpayers Representation Workshop: Timely Judicial Suits -- Carlton Smith (Cardozo), Willard Trimm (Georgia State)

May 10, 2012 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 2, 2012

The Tax Lawyer Publishes New Issue

Tax Lawyer The Tax Lawyer has published Vol. 64, No. 4 (Summer 2011), The State & Local Tax Edition:

May 2, 2012 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, April 7, 2012

ABA, NYSBA Propose Estate & Gift Tax Reforms

ABA Tax SectionThe ABA Tax Section has submitted estate, gift, and generation-skipping transfer tax reform ideas (55 pages) to the House Ways & Means Committee and Senate Finance Committee in the following ten categories:

  1. Need for Predictability and Stability in Federal Transfer Tax System
  2. Unification of the Federal Estate and Gift Tax Exclusion Amounts
  3. Portability of the Exemptions
  4. Section 6166
  5. Valuation of Interests in Closely Held Entities
  6. "Clawback" or "Recapture" of Transfer Tax on Gifts Protected by Gift Tax Unified Credit
  7. Annual Exclusion
  8. Generation-Skipping Transfer Tax Provisions
  9. Inter Vivos QTIP Elections
  10. Marital Deduction and Charitable Giving

NYSBAThe New York State Bar Association Tax Section has released Report on Portability of the Estate Tax Exemption (13 pages)

Unless extended, portability of the estate tax exclusion will sunset on December 31, 2012. In this report, we have recommended several changes to the existing statute that we believe better serve the basic policy objectives of the current portability rules, all based on the assumption that it is extended beyond 2012. Specifically, we recommended that (i) any revised statute retain rather than modify the current definition of DSUEA, (ii) Example 3 from the 2010 JCT Explanation be revised to conform to the unmodified definition of DSUEA, and (iii) any revised statute clarify that taxable gifts on which gift tax was paid by the last deceased spouse are excluded from the Section 2010(c)(4)(B)(ii) amount. We have also recommended that any revised statute clarify certain issues a surviving spouse would face concerning the amount and use of the DSUEA if he or she were to remarry after a valid portability election is in effect.

April 7, 2012 in ABA Tax Section, NYSBA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, March 20, 2012

2012 Tannenwald Tax Writing Competition

Tannenwald Writing Competition_Page_1

For students writing tax seminar papers this semester (or having completed a tax paper last semester):  the Theodore Tannenwald, Jr. Foundation for Excellence in Tax Scholarship and American College of Tax Counsel are sponsoring the 2012 Tannenwald Writing Competition:

Named for the late Tax Court Judge Theodore Tannenwald, Jr., and designed to perpetuate his dedication to legal scholarship of the highest quality, the Tannenwald Writing Competition is open to all full- or part-time law school students, undergraduate or graduate. Papers on any federal or state tax-related topic may be submitted in accordance with the Competition Rules.

Prizes:

  • 1st Place:  $5,000, free trip to the 2013 ABA Tax Section Mid-Year Meeting in Orlando, and publication in the Florida Tax Review
  • 2nd Place:  $2,500
  • 3rd Place:  $1,500

Deadline:  9:00 p.m. EST, July 3, 2012. Mail papers to: Tannenwald Foundation, Ste. 200, 1275 Pennsylvania Ave., N.W., Washington, D.C. 20004, Attn: Melnie Moore.

For more information, contact Nancy Abramowitz.

For a list of participating law schools, see here. For a list of winners from prior years, and their tax faculty sponsors, see here.

March 20, 2012 in ABA Tax Section, Legal Education, Scholarship, Tax, Teaching | Permalink | Comments (0) | TrackBack (0)

Monday, March 5, 2012

Vanderbilt, Northwestern Win 2011 ABA Law Student Tax Challenge

ABA LSTCThe ABA Tax Section has released the list of winners of the 2011 Law Student Tax Challenge:

An alternative to traditional moot court competitions, the Law Student Tax Challenge asks two-person teams of students to solve a cutting-edge and complex business problem that might arise in everyday tax practice.

J.D. Division:

  • Vanderbilt1st Place:  Vanderbilt -- Emily Klick & Joshua Rabon (Herwig Schlunk, faculty coach)
  • 2nd Place:  W. New England -- Nicole Dunk & Joseph Horvath (Frederick Royal, faculty coach)
  • 3rd Place:  Oklahoma -- Jessica Cory & Brandee Raney (Jonathan Forman, faculty coach)
  • Best Written Submission:  Vanderbilt -- Emily Klick & Joshua Rabon (Herwig Schlunk, faculty coach)
  • Semi-finalist #1:  Cleveland State -- Benjamin Heidinger & C. Timothy Murphy (John Plecnik, faculty coach)
  • Semi-finalist #2:  Chapman -- Aaron Waites & Morgan Windbiel (Peter van Zante, faculty coach)
  • Semi-finalist #3:  Florida -- Stephanie Malen & B. Caitlin Foster (Steven Willis, faculty coach)

LL.M. Division:

  • Northwestern1st Place:  Northwestern -- Julie Green & Genevieve Tokic (Philip Postlewaite,  faculty coach)
  • 2nd Place:  Northwestern -- Andrew Oppenheimer & John Barron (Charlotte Crane, faculty coach)
  • Best Written Submission:  Northwestern -- Ena Patel & Joel Boussert (Herbert Beller, faculty coach)
  • Finalist #1:  Denver -- Samantha Karr & John McGuire (Alicia Buckingham, faculty coach)
  • Finalist #2:  Northwestern -- Ena Patel & Joel Boussert (Herbert Beller, faculty coach)

March 5, 2012 in ABA Tax Section, Legal Education, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, February 17, 2012

ABA Tax Section Midyear Meeting

ABA Tax SectionThe ABA Tax Section midyear meeting continues today in San Diego. The full program is here. Tax Profs with speaking roles today include:

  • Administrative Practice:  The Administrative Procedure Act and Tax Administration: How Does it Apply? What Is the Debate? What Do Tax Professionals Need to Know? -- Kristin Hickman (Minnesota)
  • Bankruptcy & Workouts: Acquisition of Troubled Corporations -- Don Leatherman (Tennessee)
  • Diversity: Could 9-9-9 Ever Really Work? Considering Alternative Taxation Structures on the Road to a Fairer, Simpler Tax System -- Linda Beale (Wayne State), Julie Manasfi (Whittier)
  • Employee Benefits:  Employee Benefits Distributions Update -- Kathryn J. Kennedy (John Marshall)
  • Exempt Organizations:  The Future of the Charitable Deduction -- Ellen P. Aprill (Loyola-L.A.)
  • Foreign Activities of US Taxpayers: Foreign Tax Credits -- Mark S. Hoose (San Diego)
  • Insurance Companies: DOMA vs. the States, with Tax Rules in the Middle -- Patricia Cain (Santa Clara)
  • Partnerships & LLCs:  Hola, Ni Hao, Shalom, Say Hello to Your Foreign Partner -- Noel P. Brock, (West Virginia)

February 17, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, February 16, 2012

ABA Tax Section Names 2012 Nolan Fellows

ABA Tax Section Logo The ABA Tax Section has announced the recipients of its 2012 Nolan Fellowships at ts midyear meeting in San Diego:

Named for the late Jack Nolan, a dedicated and respected Tax Section member, the distinction is awarded to young lawyers who are actively involved in the Section and have shown leadership qualities. Each one-year fellowship includes waived Meeting registration fees and assistance with travel to some Section meetings.

February 16, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, February 15, 2012

ABA Tax Section Midyear Meeting

LewisThe ABA Tax Section midyear meeting kicks off today in San Diego. With the opening of the meeting came news of the death of Stuart Lewis (Buchanan Ingersoll & Rooney, Washington, D.C.), Chair of the ABA Tax Section in 2009-10. Mr. Lewis (B.A. 1967, Virginia; J.D. 1970, Virginia), was an Adjunct Professor in Georgetown's Graduate Tax Program; Fellow of the  American Bar Foundation and American College of Tax Counsel; and Member of the Board of Advisors of the Virginia Tax Review and NYU Law School. From the memorandum released to Section Members:

Stuart contributed greatly to the work of the Section and to the administration of the tax system. He had a witty, dry sense of humor and even through trying times had a twinkle in his eye. He cared about the next generation of tax lawyers and was always willing to lend a helping hand. We admire his courage and we extend our condolences to his wife, Bronwen, and his family. In keeping with Stuart's wishes, his immediate family plans to spread his ashes on the family farm in Culpeper, Virginia. A funeral service will not be held.

In place lieu of flowers, the family requests that those who wish to make donations please support the following:

(Hat Tip: Francine Lipman.)

February 15, 2012 in ABA Tax Section, Conferences, Obituaries | Permalink | Comments (0) | TrackBack (0)

ABA Tax Section Publishes Winter 2012 Issue of News Quarterly

Page 1_Page_1The ABA Tax Section has published 31 News Quarterly No. 2 (Winter 2012):

February 15, 2012 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, December 7, 2011

ABA Submits Comment Letter on Tax Reform and Partnerships

ABA Tax SectionThe ABA Tax Section has submitted a comment letter to the House Ways & Means Committee and Senate Finance Committee, Options for Tax Reform Relating to Partnerships (18 pages), on these topics:

  1. Partners as Employees
  2. Income from Self-Employment of Limited Partners
  3. Hot Assets Under Section 751(b)
  4. Section 465 At-Risk Rules
  5. Section 708(b)(1)(B) Technical Termination
  6. Section 197(f)(9) Antu-CHurning Rules
  7. Expand section 108(e)(6) to Cover Partnerships

December 7, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, November 8, 2011

The Tax Lawyer Publishes New Issue

Tax Lawyer The Tax Lawyer has published Vol. 64, No. 3 (Spring 2011):

November 8, 2011 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, November 2, 2011

ABA Tax Section Publishes Fall 2011 Issue of News Quarterly

NewsquarterlyThe ABA Tax Section has published 31 News Quarterly No. 1 (Fall 2011):

November 2, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, October 25, 2011

Pro Bono

As part of National Pro Bono Celebration Week, the ABA Tax Section is offering three webcasts this week:

Tax Court Controversy: The Nuts and Bolts of Pro Bono Representation (Oct. 25)
Providing pro bono assistance to low income taxpayers is a valuable service to the community and a rewarding experience. Many tax practitioners are surprised at how transferable tax controversy skills are to their daily tax practice, whether that is transactional work or litigation. However, it can seem overwhelming to get a handle on the basics of a tax controversy case if one has limited experience with the US Tax Court or the IRS. This webcast provides the basics of handling a pro bono tax controversy matter from initial client contact through the various types of cases (audits, appeals, litigation, collections, investigations, etc.).

Panelists
Caroline D. Ciraolo, Rosenberg | Martin | Greenberg (Baltimore)
James Leith, Local Taxpayer Advocate for Maryland (Baltimore)
Catherine B. Engell, DLA Piper (New York)

U.S. Tax Court Pro Bono Programs (Oct. 26)
Tax clinics and Bar-related pro bono programs provide important advice and assistance to many low-income, otherwise unrepresented taxpayers who have disputes with the Internal Revenue Service. This webcast provides information on how these pro bono programs work from varying perspectives of all the key players. In addition, attorneys will receive information on how to get involved or coordinate a United States Tax Court Pro Bono Program in their area.

Panelists
Hon. Peter J. Panuthos (U.S. Tax Court)
Nancy C. Carver (IRS, SB/SE)
Stephen C. Lessard (Orrick, Herrington & Sutcliffe, New York)
Frank Agostino (Agostino & Associates, Hackensack, NJ)

Federal Income Tax Issues Facing Unauthorized Workers and Their Families (Oct. 27)
This webcast will provide a primer on federal income tax substantive and compliance issues facing unauthorized workers residing in America today. The complexity of the federal income tax issues facing these workers and their families is staggering given the intersection of traditional low-income tax matters (e.g., filing status, child tax credits, dependency exemption issues), immigration status, and the challenges of compliance where the taxpayers are not able to obtain a Social Security number.

Panelist
Francine J. Lipman (Visiting Professor, UNLV)

October 25, 2011 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, October 22, 2011

ABA Tax Section Midyear Meeting

ABA Tax Section LogoThe ABA Tax Section Fall meeting concludes today in Denver. The full program is here. Tax Profs with speaking roles today include:
  • Employee Benefits and Employee Benefits Group: Ethics Issues in Employee Benefits -- Andrew M. Perlman (Suffolk)
  • Low Income Taxpayers: Benefits and Pitfalls of Advanced Pre-Refund Compliance Checks -- Keith Fogg (Villanova), Scott Schumacher (U. Washington)
  • Pro Bono: Identity Theft vs. Fourth Amendment and Taxpayer Privacy Rights: The Case of Amalia’s Translation and Tax Services in Greeley, CO -- Francine J. Lipman (UNLV)
  • Pro Bono: Update on Pro Bono Matters -- Francine J. Lipman (UNLV)
  • Sales, Exchanges & Basis: Check-the-Box Bramblett -- Bradley T. Borden (Brooklyn)
  • Sales, Exchanges & Basis: Non-§1031 Current Developments -- Erik M. Jensen (Case Western)
  • Section Program: Next Generation Disputes in the Family Business: Navigating the Remedial, Ethical and Tax Quagmires -- A Case Study -- Mark J. Loewenstein (Colorado)
  • Section Program: Representing Your Client Before the Tax Court -- Keith Blair (District of Columbia), Jack Snyder (Baltimore)

October 22, 2011 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, October 21, 2011

ABA Tax Section Midyear Meeting

ABA Tax Section LogoThe ABA Tax Section Fall meeting continues today in Denver. The full program is here. Tax Profs with speaking roles today include:
  • Administrative Practice: Taxpayer Reliance on “Formal” and “Informal” IRS Guidance -- Kristin Hickman (Minnesota)
  • Affiliated & Related Corporations: Consolidated Section 382 and the SR LY Rules: Can They Be Refined and Simplified? -- Don Leatherman (Tennessee)
  • Court Procedure & Practice: Common Evidentiary Issues in Tax Cases -- Joni Larson (Thomas Cooley)
  • Employee Benefits Distributions Update -- Kathryn J. Kennedy (John Marshall)
  • Exempt Organizations and Charitable Planning & Organizations: Gift Tax on Transfers to Section 501(c)(4) Organizations -- Ellen P. Aprill (Loyola-L.A.)
  • Individual & Family Taxation: IRS Collection -- Is the Pendulum in the Right Place? -- Scott A. Schumacher (U. Washington)
  • Standards of Tax Practice: Recent Amendments to Circular 230 and Their Potential Impact on Practitioner Disciplinary Proceedings -- Linda M. Beale (Wayne State)
  • Task Force on Patenting Tax Strategies -- Ellen P. Aprill (Loyola-L.A.)
  • Tax Practice Management: Ethics in Estate Planning -- Michael B. Lang (Chapman)
  • Teaching Taxation: Three Views of Supreme Court Tax Jurisprudence -- Adam S. Chodorow (Arizona State), Charlotte Crane (Northwestern), Nancy Staudt (USC)
  • Young Lawyers Forum & Diversity: Critical Tax Theory: The Impact of the Tax Code on Traditionally Subordinated Groups -- Anthony C. Infanti (Pittsburgh), Francine J. Lipman (UNLV)

October 21, 2011 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, October 17, 2011

Mason Presents Federal-State Tax Base Conformity Today at Loyola-L.A.

Mason Ruth Mason (Connecticut) presents Delegating Up: Federal-State Tax Base Conformity at Loyola-L.A. today as part of its Tax Policy Colloquium Series:

Congress uses the income tax to regulate. Because states impose their own income taxes on the federally-defined income tax base, rather than on separately determined state tax bases, states automatically import federal policies into their own tax systems. But federal tax policies reflect national, not local, political choices. This Article calls attention to the practice of tax base conformity and to its advantages and drawbacks. Conformity conserves legislative, administrative, and judicial resources, and it reduces taxpayers’ compliance burdens. At the same time, however, conforming states cede tax autonomy to the federal government, thereby exposing themselves to revenue volatility stemming from the ever-changing federal tax law. Additionally, conformity jeopardizes the values served by federalism, including regulatory competition, diffusion of power, promotion of local values and policy preferences, and policy experimentation. Conformity also imports the defects of the federal tax base into state tax law. While the significant administrative and compliance advantages of federal-state tax base conformity suggest that it is here to stay, this Article makes recommendations for reducing its adverse impacts and for further study.

Kirk J. Stark (UCLA) is the commentator.

October 17, 2011 in ABA Tax Section, Colloquia, Scholarship, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, October 11, 2011

ABA Tax Section Accepting Nominations for 2012-14 Public Service Fellowships

ABA Tax Section The ABA Tax Section is accepting applications for Public Service Fellowships for 2012-2014:

Applications must be received by November 1, 2011 to be considered. Applicants selected for interviews will be invited to attend the Section’s meeting in on February 16-18, 2012, and asked to participate in interviews on February 18, 2012.

Continue reading

October 11, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Monday, October 10, 2011

ABA Tax Section Seeks Nominations for Janet R. Spragens Pro Bono Award

ABA Tax Section The ABA Tax Section is soliciting nominations for the 2012 Janet Spragens Pro Bono Award to be presented at the January 2012 Midyear Meeting in San Diego. The award recognizes one or more individuals or law firms that have provided meritorious pro bono service in the representation of low-income taxpayers:

The award may be based upon any of the following criteria:

  • Handling a significant number of tax controversies for low-income taxpayers on a pro bono basis over an extended period of time, or intensive involvement over a limited time with significant impact
  • Voluntarily forming, operating or participating in organizations, such as low-income taxpayer clinics (LITCs) devoted to representation of low-income taxpayers, particularly if such participation is over an extended period
  • Formation, supervision and participation in programs to assist tax controversies, including “attorney of the day” programs for the Tax Court
  • Mentoring law students and other individuals who work for LITCs
  • Preparation of resource materials for LITCs and other low-income programs
  • Providing pro bono legal assistance to tax-exempt organizations, especially those formed to help low-income taxpayers

Please submit nominations on the online nomination form by November 14, 2011.

October 10, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, September 20, 2011

ABA Tax Section Pro Bono Committee Launches New Website

ABA Tax Section Logo The ABA Tax Section Pro Bono Committee has launched a new website:

Vice Chairs Catherine B. Engell (DLA Piper LLP, NY, NY) and Brian David Yacker (Long Beach, CA) join me in welcoming you to the Pro Bono Committee Website!

As the new Chair of the Pro Bono Committee I am hopeful that we can make this website "the go to link" for all of your tax Pro Bono matters, concerns, issues, thoughts, dreams and goals. Toward that goal I hope you will send any and all of your relevant materials to me for posting and broad distribution.

As you know the ABA - Section of Taxation is over 20,000 strong!! Therefore, we have an amazing team, network of deep and broad resources that can make a difference in the lives of everyday people across America. I have volunteered to serve in this role, because I know that it is an enormous privilege and pleasure to give to others especially something as extraordinary as our tax training and skills. As a law professor I bear witness almost every day to the steep learning curve and complexity inherent in our tax systems. This committee is a bridge between the haves and the have nots. I welcome and encourage your participation in any capacity. So please send me any and all of your suggestions, ideas, problems and solutions via email at Francine.Lipman@UNLV.edu

Warmest regards,

Francine J. Lipman

 

September 20, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, August 23, 2011

The Tax Lawyer Publishes New Issue

Tax Lawyer The Tax Lawyer has published Vol. 64, No. 2 (Winter 2011):

August 23, 2011 in ABA Tax Section, Scholarship, Tax | Permalink | Comments (2) | TrackBack (0)

Friday, August 19, 2011

ABA Tax Section Publishes Summer 2011 Issue of News Quarterly

NQ The ABA Tax Section has published 30 News Quarterly No. 4 (Summer 2011):

August 19, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Tuesday, August 2, 2011

ABA Tax Section Submits Comments on § 355(d) Regs

ABA Tax The ABA Tax Section has submitted comments on § 355(d) to the IRS:

In these Comments, we identify certain specific areas in which the regulations do not adequately address inconsistencies between the mechanical rules and the purposes underlying § 355(d), and we request new guidance to eliminate these inconsistencies.

August 2, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Sunday, July 31, 2011

ABA Tax Section Submits Comments on 2011-12 Guidance Priority List

ABA Tax The ABA Tax Section has submitted this 18-page comment letter to the IRS with recommendations for the IRS's 2011-2012 Guidance Priority List:

As requested in Notice 2011-39, the ABA Section of Taxation has identified the following tax issues that we recommend be addressed through Regulations, rulings or other published guidance in 2011-2012. In each case, the name and contact information for a representative of the committee making the suggestion are provided.

July 31, 2011 in ABA Tax Section, IRS News, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, July 14, 2011

ABA Tax Section Submits Comments on Final Circular 230 Regs

ABA Tax The ABA Tax Section has submitted this comment letter to the IRS on the final Circular 230 regulations:

The final Regulations included significant changes with regard to which there was no opportunity to comment. We believe that some of the changes may have unintended negative consequences. Specifically, the removal of references to the Office of Professional Responsibility (“OPR”) is of concern.

July 14, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, June 10, 2011

ABA Tax Section Chair Challenges Congress: Put Tax Lawyers Out of Business

Tax Analysts Amy S. Elliott, ABA Tax Section Chair Challenges Congress to Put Tax Lawyers Out of Business, 2011 TNT 112-8 (June 10, 2011):

The chair of the ABA Section of Taxation, unfazed by the prospect of losing 22% of the section's membership -- which occurred after the enactment of the Tax Reform Act of 1986 -- said June 9 that the tax code is in desperate need of another overhaul.

"The goal that Congress ought to have is to put as many of us out of business as possible. Now I say that with full confidence that it's not going to happen," said Charles H. Egerton. Although Congress may stop short of completely restructuring the code, he said, "we'll have to reinvent ourselves. That's a price we need to be willing to pay."

All Tax Analysts content is available through the LexisNexis® services.

June 10, 2011 in ABA Tax Section, Tax, Tax Analysts | Permalink | Comments (3) | TrackBack (0)

Thursday, May 19, 2011

ABA Tax Section Publishes Spring 2011 Issue of News Quarterly

ABA NQ The ABA Tax Section has published 30 News Quarterly No. 3 (Spring 2011):

May 19, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

Saturday, May 7, 2011

Jerry Cohen Receives ABA Tax Section Distinguished Service Award

Cohen N. Jerold Cohen (Sutherland Asbill & Brennan, Atlanta), former IRS Chief Counsel (1979-81), received the 2011 Distinguished Service Award from the ABA Tax Section today at the conclusion of its annual May Meeting in Washington, D.C. From the press release:

“Jerry Cohen is an outstanding and committed tax lawyer,” said Charles Egerton, chair of the Section of Taxation.  “His work in the tax profession and his public service to the tax system and to the broader community is an inspiration to all.  Jerry has achieved the highest levels of success in the profession, and respect among his peers. He continues to work toward improving the legal system and to mentor and inspire young lawyers.”

Prior winners:

May 7, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

ABA Tax Section May Meeting

ABA Tax Section Logo The ABA Tax Section May meeting concludes today in Washington, D.C. The full program is here; Tax Profs with speaking roles today include:
  • Foreign Lawyers Forum: Exploring the Terrain of Territorial Exemption Systems -- Stephen Shay (Harvard)
  • Low Income Taxpayers: Opening Remarks by the Chair: Kathryn Sedo (Minnesota)
  • Low Income Taxpayers: What's Next? -- Kristin Hickman (Minnesota), Kathryn Sedo (Minnesota), Carlton Smith (Cardozo)
  • Pro Bono: Update on Projects -- Francine Lipman (Chapman)
  • Pro Bono: Role of the National Taxpayer Advocate -- Leslie Book (Vilanova), Bryan Camp (Texas Tech)
  • Sales, Exchanges & Basis: Non-§ 1031 Current Developments -- Erik Jensen (Case Western)
  • Sales, Exchanges & Basis: Section 1031 Developments -- Brad Borden (Brooklyn)

May 7, 2011 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Friday, May 6, 2011

ABA Tax Section May Meeting

ABA Tax Section Logo The ABA Tax Section May meeting continues today in Washington, D.C. The full program is here; Tax Profs with speaking roles today include:
  • Banking and Savings Institutions, Financial Transactions, Insurance Companies, Investment Management and Tax Exempt Financing Committees Luncheon --Richard Harvey (Villanova)
  • Bankruptcy & Workouts: IRS Expense Standards -- Kristin Hickman (Minnesota)
  • Court Procedure & Practice: Common Evidentiary Issues In Tax Cases -- Joni Larson (Thomas Cooley)
  • Employee Benefits Distributions Update -- Kathryn Kennedy (John Marshall)
  • Financial Transactions: Upfront Payments: Cash Without Taxation? -- Dana Trier (Miami)
  • Individual and Family Taxation: Divorce Taxation -- Patricia Cain (Santa Clara), David Rice (Pomona)
  • Individual and Family Taxation: Tax Simplification: Individuals and Families -- Adam Chodorow (Arizona State), Martin McMahon (Florida)
  • Partnerships & LLCs: To Book-Up, or Not to Book-Up, That is the Question -- Howard Abrams (Emory)
  • Standards of Tax Practice: Ethical Implications of DOJ Decision Not to Enforce the “Defense of Marriage Act -- Linda Beale (Wayne State)
  • Standards of Tax Practice: Resolved: That the Standards for Tax Return Positions of Circular 230 Section 10.34 Should Conform in All Respects to the Standards Prescribed by § 6694 -- Linda Beale (Wayne State)
  • Task Force on Patenting Tax Strategies -- Ellen Aprill (Loyola-L.A.) (Co-Chair)
  • Tax Policy and Simplification: Opening Remarks by Chair -- Reuven Avi-Yonah (Michigan)
  • Tax Policy and Simplification: Tax Reform and Deficit Reduction: Proposals, Implementation, and Policy Considerations, Part I (Administrative and Legislative Perspectives) -- John Buckley (Georgetown), Jonathan Forman (Oklahoma)
  • Tax Policy and Simplification: Tax Reform and Deficit Reduction: Proposals, Implementation, and Policy Considerations, Part II (Policy Commentary) -- Mona Hymel (Arizona), David Cay Johnston (Syracuse), Martin McMahon (Florida)
  • Teaching Taxation: Opening Remarks by the Chair -- Tracy Kaye (Seton Hall)
  • Young Lawyers Forum & Diversity; The Defense of Marriage Act (DOMA) and the Internal Revenue Code -- Patricia Cain (Santa Clara)

May 6, 2011 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Thursday, May 5, 2011

ABA Tax Section Publishes Winter 2011 Issue of News Quarterly

ABA Newsletter The ABA Tax Section has published 30 News Quarterly No. 2 (Winter 2011):

May 5, 2011 in ABA Tax Section, Tax | Permalink | Comments (0) | TrackBack (0)

ABA Tax Section May Meeting

ABA Tax Section Logo The ABA Tax Section May meeting kicks off today in Washington, D.C. The full program is here; Tax Profs with speaking roles today include:
  • Low Income Taxpayers Representation Workshop: Communicating by Mail with the IRS -- Keith Fogg (Villanova)
  • Low Income Taxpayers Representation Workshop: Face to Face Meetings in Audits and Appeals, including CDP Hearings -- Diana Leyden (UConn), Kathryn Sedo (Minnesota)
  • Low Income Taxpayers Representation Workshop: IRS E-Services -- George Willis (Chapman)

Francine Lipman (Chapman) is spearheading an effort on behalf of the Pro Bono Committee to have ABA Tax Section members work with local organizations today in providing free tax assistance to D.C. area residents. For more details or to volunteer, email Francine.

May 5, 2011 in ABA Tax Section, Conferences, Tax | Permalink | Comments (0) | TrackBack (0)

Wednesday, May 4, 2011

ABA Tax Section Submits Comment Letters

A Practitioner's Guide to Innocent Spouse Relief

Guide The ABA has published A Practitioner's Guide to Innocent Spouse Relief, by Robert B. Nadler (Tennessee taxpayer Project):

Thousands of Innocent Spouse claims are filed each year -- this comprehensive and concisely written guide provides you with the framework for representing your client successfully. In straightforward language, the Guide takes you step-by-step through the Innocent Spouse claim process, from information gathering, to administrative proceedings, to determination, to trial, and to refund relief. Learn:

  • How to advise clients going through a divorce on whether to file a joint or a separate return.
  • How to represent the client who did not meet his or her "duty to inquire" when he or she signed the return.
  • When to argue duress and when to argue abuse in innocent spouse cases.
  • When the IRS can grant innocent spouse relief even though the tax is attributable to your client's income.
  • When it might be in your client's best interests to oppose the IRS granting relief.
  • When it is possible to file a claim for innocent spouse relief after the two-year limitations period has expired.
  • How to use discovery to identify which equitable relief factors are in dispute.
  • When to file a motion to shift the burden of proof to the IRS.
  • How to recover reasonable costs and attorney fees in innocent spouse cases.
  • When and how to recover refunds in innocent spouse controversies.

Table of Contents, Foreword

May 4, 2011 in ABA Tax Section, Book Club, Tax | Permalink | Comments (0) | TrackBack (0)