Paul L. Caron
Dean





Wednesday, May 24, 2006

Microsoft iPod

Non-tax, but hilarious: what the iPod box would look like if it were designed by Microsoft, rather than by Apple:

The kicker is that the spoof was produced by designers at Microsoft as an exercise of self-criticism! (Hat Tip:  Wall Street Journal.)

May 24, 2006 in Celebrity Tax Lore | Permalink | Comments (0) | TrackBack (1)

Pozen on Remapping the Charitable Deduction

Ssrn_73 David Pozen (Yale J.D. 2007) has posted Remapping the Charitable Deduction, 39 Conn. L. Rev. ___ (2006), on SSRN.  Here is the abstract:

If charity begins at home, scholarship on the charitable deduction has stayed at home. In the voluminous literature on the deduction, few authors have engaged the distinction between charitable contributions that are meant to be used within the United States and charitable contributions that are meant to be used abroad. Yet these two types of contributions are treated very differently in the Code, and raise very different policy issues. As Americans' giving patterns and the U.S. nonprofit sector become increasingly international, the distinction will only become more salient in the years to come.

This Article offers the first exploration of how theories of the charitable deduction apply to internationally-targeted donations. In so doing, the Article aims to inspire not only a methodological shift in nonprofit tax scholarship (a strategic remapping), but also a reappraisal of the deduction literature (an analytic remapping): Just as existing theories of the deduction can inform our understanding of foreign charity, considerations of foreign charity can shed light back on the existing theories.

Continue reading

May 24, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

What Is the Most Heavily-Cited Tax Case?

My friend and colleague Adam Steinman just handed me a reprint of his article, The Irrepressible Myth of Celotex: Reconsidering Summary Judgment Burdens Twenty Years after the Trilogy, 63 Wash. & Lee L. Rev. 81 (2006).  Although the subject matter likely is of little interest to most readers of this blog, Adam unearthed a fascinating tidbit:  apparently there has been little empirical work identifying the most frequently cited cases.  With the help of LexisNexis, Adam published fascinating charts in his appendix (at pages 143-45) of the 15 most-cited cases by federal courts and tribunals and the 30 most-cited cases by federal and state courts and tribunals.  Here are the 10 most-cited cases from the latter chart:

Steinman_sct_citation_charts_1

There is not a tax case in any of Adam's charts.  So that got me to thinking:  what are the most heavily cited tax cases?  Is there any empirical work addressing the question?  Comments are open.

In our Tax Stories book, we took a stab at identifying what we think are the ten most influential income tax cases of all time.  Here is a back of the envelope calculation of the federal citations to the ten cases in Tax Stories:

Tax_citations_2

Some of these results are surprising (at least to me), especially the dominance of Welch v. Helvering and the comparatively weak showing of Knetsch and Crane.  What other tax cases belong on this list?

For more on Tax Stories:

May 24, 2006 in Scholarship | Permalink | Comments (3) | TrackBack (2)

Michigan Hosts Conference on Transfer Pricing in Beijing

Peking_1 Michigan_2Michigan University and Peking University hosted a Conference on Transfer Pricing last week in Beijing, China.  Reuven Avi-Yonah (Michigan) was the conference co-chair, and several U.S. Tax Profs participated:

  • Reuven co-chaired Session #1 on Harmonious Society & Tax Judicial Reform
    • Judge David Laro presented Transfer Pricing in the United States Tax Court
    • Jeffrey Lehman presented Tax Policy and Income Security in a Global Economy
  • Yariv Brauner (Arizona State) co-chaired Session #2 on Challenges of Transfer Pricing in the 21st Century
    • Reuven presented The Problems and Challenges of American Transfer Pricing System
  • Session #3:  Discussions on Transfer Pricing System in Some Domains
    • Yariv presented Transfer Pricing in Intangible and Service
  • Session #4:  Advance Pricing Arrangement --- The Approach to Solve the Dilemma of Transfer Pricing System?
    • Diane M. Ring (Boston College) presented Inside the United States APA Program

May 24, 2006 in Tax Conferences | Permalink | Comments (0) | TrackBack (0)

Sialm on Investment Taxes and Equity Returns

Sialm Ssrn_logo_142 Clemens Sialm (University of Michigan, Ross School of Business) has posted Investment Taxes and Equity Returns on SSRN.  Here is the abstract:

This paper investigates whether investors are compensated for the tax burden of equity securities. Effective tax rates on equity securities vary due to frequent tax reforms and due to persistent differences in propensities to pay dividends. The paper finds an economically and statistically significant relationship between risk-adjusted stock returns and effective personal tax rates using a new data set covering tax burdens on a cross-section of equity securities between 1927 and 2004. Consistent with tax capitalization, stocks facing higher effective tax rates tend to compensate taxable investors by generating higher before-tax returns.

May 24, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Tuesday, May 23, 2006

ABA Tax Section Submits Comments to IRS on § 7874

Aba_tax_7 The ABA Tax Section has submitted comments to the IRS on the proposed regulations under § 7874.  Here is the opening of the Executive Summary:

The American Jobs Creation Act of 2004 added § 7874 to curtail inversion transactions. In December of 2005, the Treasury Department issued proposed and temporary regulations setting forth rules for disregarding affiliate owned stock in determining whether an inversion subject to § 7874 has occurred. The legislative history describes the paradigm transaction, which was the focus of the legislation - “[a] U.S. corporation may reincorporate in a foreign jurisdiction and thereby replace the U.S. parent corporation of a multinational corporate group with a foreign parent.” The legislation was drafted to capture both stock inversions and asset inversions including various combinations of, and variations to, such transactions. Congress believed that inversion transactions resulting in minimal business presence in a foreign country were primarily designed to avoid U.S. tax. Accordingly, § 7874 identifies inversion transactions deemed motivated primarily for U.S. tax avoidance purposes and imposes harsh sanctions.

May 23, 2006 in ABA Tax Section | Permalink | Comments (0) | TrackBack (0)

An Etiquette Guide for Law School

Check out this somewhat ribald An Etiquette Guide for Law School by a University of Chicago law student:

May 23, 2006 in Law School | Permalink | Comments (0) | TrackBack (0)

GAO Releases Report on IRS Offers in Compromise

Gao_6The Government Accountability Office today released IRS Offers in Compromise: Performance Has Been Mixed; Better Management Information and Simplification Could Improve the Program (GAO-06-525).  Here are the Results in Brief:

OIC Program performance has been mixed. Timeliness improved for taxpayers making one offer to 5.8 months in 2005 but stayed constant, at an average of two years, for those making repeat offers. Quality goals have been met but IRS does not routinely track compliance and accessibility. Further, cost per offer has increased in that IRS has not decreased staffing since fiscal year 2003 in proportion to declines in offers. Improving the program depends on how well IRS management understands the reasons for the program’s performance. One step in understanding performance is measuring it. However, IRS does not measure timeliness from the perspective of the taxpayer—for taxpayers with repeat offers IRS measures the time to decide each offer but not the overall time to resolve the taxpayer’s liability. IRS lacks compliance and accessibility trend data useful for assessing performance. Another step in understanding performance is setting goals. IRS set numeric goals for timeliness and quality, but IRS’s timeliness goals do not have a rationale and are not based on taxpayer needs or other benefits. A third step in understanding performance is analysis. While IRS has done some analyses that led to program changes, IRS has not analyzed the effect of repeat offers on timeliness to determine whether it would be less costly to deal once with a taxpayer rather than have to process repeat offers. IRS also has not analyzed whether the decrease in offers accepted since fiscal year 2003 reflects a decrease in program accessibility, or whether the efforts to improve the compliance of program participants have been successful.

Continue reading

May 23, 2006 in Gov't Reports | Permalink | Comments (0) | TrackBack (0)

Bank on A Capital Lock-In Theory of the Corporate Income Tax

Bank_9Steven A. Bank (UCLA) has published A Capital Lock-In Theory of the Corporate Income Tax, 94 Geo. L.J. 889 (2006).  Here is the abstract:

The separate taxation of corporations has attracted significant attention recently, but it has yet to be adequately explained. In part, this may be because the understanding of the corporation itself has been insufficiently developed. Recently, however, scholars have begun to study a new feature of the corporation - its ability to lock-in capital and the earnings from capital - that has been overlooked and may offer hope in understanding the corporate tax. Capital lock-in may be economically beneficial for firms with long-range investments and firm-specific assets, but it poses difficulty for a progressive individual income tax system. Unless shareholders are taxed currently on undistributed corporate earnings, there is a risk of deferral because dividends are at the discretion of the board of directors. Imposing pass-through taxation, however, could threaten capital lock-in and incur the wrath of corporate managers. At an early point, this tension was resolved by imposing a corporate tax that levied a current charge on earnings, but under its own rate structure to minimize any distributive pressure from the historically high marginal rates applicable to individuals. While much has changed in the income tax system in the last century, this compromise continues to describe our system. Whether it is a compromise that has value is something that merits further study as part of the current consideration of fundamental tax reform.

May 23, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

50-State Economic Freedom Ranking

The Pacific Research Institute has released the Economic Freedom Index, modeled after the Index of Economic Freedom, published by The Brookings Institution and the Wall Street Journal, which ranks the 161 countries in the world by 50 variables in 10 categories (trade policy, fiscal burden of government, government intervention in the economy, monetary policy, capital flows and foreign investment, banking and finance, wages and prices, property rights, regulation, and informal market activity).  The new Economic Freedom Index ranks the 50 states by 143 variables in 5 categories (fiscal, regulatory, welfare spending, government size, and judicial).

Here are the Top 10 (most free) states:

Top_10_states_1

Here are the Bottom 10 (least free) states:

Bottom_10_states

The Wall Street Journal has published an op-ed on the study by Lawrence J. McQuillan and Hovannes Abramyan of the Institute:  "Live Free or Move": Jobs Are Flocking to Low-Tax States for a Reason:

[T]he states that embraced supply-side tax cuts are not only financially more sound and enjoy stronger economies, but they are draining residents away from the states that opted for high taxes....In 2005, per capita personal income grew 31% faster in the 15 most economically free states than it did in the 15 states at the bottom of the list. And employment growth was a staggering 216% higher in the most free states.

May 23, 2006 in Think Tank Reports | Permalink | Comments (12) | TrackBack (3)

Abrams Wins University Teaching Award at Emory

Abrams_1Congratulations to Tax Prof Howard E. Abrams for winning the Williams Award for Distinguished Teaching at Emory:

Howard E. Abrams, professor of law, received the Emory Williams Award for Distinguished Teaching, Emory University's most prestigious award for teaching, during the university's commencement ceremony on May 15. Seven Emory Williams Awards are given to faculty members of the college and the graduate schools, with only one award rotated among the professional schools of the university.

For more, see the Emory press release

May 23, 2006 in Law School, Tax Profs, Teaching | Permalink | Comments (0) | TrackBack (0)

Richmond Hosts 34th Annual Estate Planning Seminar

Richmond_4The T.C. Williams School of Law at the University of Richmond hosts the 34th Annual Estate Planning Seminar today.  Tax Prof John Donaldson (William & Mary) is one of the featured speakers.  For a list of the speakers and their topics, see the program brochure.

May 23, 2006 in Tax Conferences | Permalink | Comments (0) | TrackBack (0)

Pietruszkiewicz on Does the IRS Have a Duty to Treat Similarly Situated Taxpayers Similarly?

Christopher R. Pietruszkiewicz (LSU) has published Does the Internal Revenue Service Have a Duty to Treat Similarly Situated Taxpayers Similarly?, 74 U. Cin. L. Rev. 531 (2005).  Here is part of the Introduction:

Nearly two decades ago, Professor Lawrence Zelenak considered whether the courts should require the Internal Revenue Service (IRS) to be consistent in the treatment of similarly situated taxpayers. A number of high profile cases and an intervening statutory change have occurred since his article was written, insisting that attention to this issue be revived.

Professor Zelenak concluded that “it is appropriate for courts to require the Service to afford one taxpayer the same favorable treatment it has given all other similarly-situated taxpayers, even if the treatment is inconsistent with that mandated by Congress.” I do not believe that a duty of consistency exists; however, it does not follow that the IRS has the discretion to treat similarly situated taxpayers differently....

Continue reading

May 23, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Monday, May 22, 2006

Batchelder Presents Efficiency and Tax Incentives: The Case for Refundable Credits Today at Tel Aviv University

Tel_aviv_5Batchelder_4Lily Batchelder (NYU) presents Efficiency and Tax Incentives: The Case for Refundable Credits, 59 Stan. L. Rev. ___ (2006) (with Fred T. Goldberg, Jr. & Peter R. Orszag) at Tel Aviv University today as part of its Tax Policy Colloquium: Here is the abstract:

Recent policy discussions have revealed increasingly heated debate about whether refundable tax credits are an appropriate part of the tax system. This Article seeks to reframe this debate by setting aside distributional and administrative objectives and focusing instead on a relatively overlooked issue: the efficient form for tax incentives. Based in part on original empirical findings, it concludes that the arguments put forward by refundable credit opponents generally are unpersuasive on their own terms or fail to counter efficiency-based justifications for refundable credits. In particular, we argue that uniform refundable credits are the most efficient way to structure tax incentives designed to encourage behavior generating positive externalities, absent evidence that the externalities or elasticities associated with the behavior vary by income class. The efficiency benefits of refundable credits are further magnified by their tendency to smooth household income and macroeconomic demand. In light of these findings, we conclude that serious consideration should be given to restructuring existing tax incentives, and designing new ones, as uniform refundable tax credits.

May 22, 2006 in Colloquia | Permalink | Comments (1) | TrackBack (0)

Dexter on Tax Terrorism: Investor Control Theory and Social Security Privatization

DexterBobby Lewis Dexter (Loyola-New Orleans) has published Tax Terrorism: Nasty Truths About Investor Control Theory and the Accommodation of Social Security Privatization, 57 Mercer L. Rev. 553 (2006).  Here is the Conclusion:

As a doctrine, investor control lacks firm theoretical footing. While market developments and taxpayer abuse of prevailing tax rules made change necessary, Congress effectively solved the problem by enacting TEFRA, which imposed taxes (and penalties) on premature access to variable contract earnings without resort to investor control concepts. In essence, Congress embraced and applied an undeniable access rationale, an approach fully consistent with tax theory fundamentals. The construction and deconstruction of an investor control doctrinal complex in a manner that appears to correspond conveniently with significant tax legislation has the undesirable effect of making fundamental tax theory appear to be the pawn of prevailing political sentiment. In much the same way Revenue Ruling 81-225 achieved a desirable tax result consistent with subsequent TEFRA rules governing access to variable contract earnings, Revenue Ruling 2003-91 appears to be a pre-emptive theoretical accommodation of Social Security privatization and the individual investor discretion privatization contemplates. Otherwise, the pronouncement represents a sudden, inexplicable liberalization of well-established rules.

Continue reading

May 22, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

WSJ: Florida Snowbirds Challenge Fairness Of Two-Tier Tax

Wsj_7 Interesting front-page article in today's Wall Street Journal:  Florida Snowbirds Challenge Fairness Of Two-Tier Tax, by Rafael Gerena-Morales:

All across the country, homeowners are complaining about runaway property taxes. In many places, sharp increases in home values are to blame. But Florida's snowbirds are angry about something else -- an unusual dual-bracket tax system. Florida allows municipalities to set the taxable value of properties at different levels for permanent and seasonal residents. There have been cases of snowbirds paying property taxes 10 times as high as those of permanent residents living nearby....

Two mobile homes on lots of the same size on the same street in Port St. Lucie, Fla., have very different property taxes. The seasonal resident who owns one home, top, pays $3,007 a year, while the permanent resident who owns the second home pays $271....

Florida's two-tier system is rooted partly in a "homestead" exemption that dates back many years. The exemption currently provides permanent residents of the state with an automatic $25,000 reduction in the assessed value of their primary homes. In addition, an amendment to the state constitution that went into effect in 1995, called Save Our Homes, caps the annual increase in assessed property values and taxes at 3% or the rate of inflation, whichever is lower. That too applies only to the primary homes of permanent residents....

Pat Thacke, 61, a New Jersey resident with a two-bedroom condominium in Port St. Lucie, says she has called 25 Florida law firms looking for someone to handle a lawsuit challenging the constitutionality of Florida's property-tax system. For 35 years, she and her husband have spent part of each year in Florida. This year they expect to pay more than $4,000 in property taxes, while a permanent Florida resident with an identical unit across the hall will likely pay about $750, she calculates. So far, she has been unable to find a lawyer willing to handle a suit....

May 22, 2006 in News | Permalink | Comments (3) | TrackBack (0)

SOI Releases Corporation Source Book, 2003

Irs_logo_188The Statistics of Income Division has released Corporation Source Book, 2003:

Data tables from the Tax Year 2003 Corporation Source Book of Statistics of Income (Publication 1053) are now available in Excel spreadsheets for viewing or downloading from Tax Stats at the IRS.gov Web site. These tables present detailed income statement, balance sheet, tax, and selected items, by industrial sector, and major and minor industrial groups. For each industrial group, the data are further classified by size of total assets. Data are presented for all corporate returns and for those returns with net income. Separate statistics on S corporations are also included by industrial sector and asset size. Data from the Tax Years 2001 and 2002 Corporation Source Book publications will be available later this year. Tax Stats contains other statistics from corporation income tax returns, as well as statistics from other types of entities (e.g., individuals, exempt organizations, and partnerships).

May 22, 2006 in IRS News | Permalink | Comments (0) | TrackBack (0)

IRS Accepts Tax Software Glitch As Excuse for Late Election

Irs_logo_252In a pair of identical private letter rulings released on Friday (200620018 & 200620019), the IRS exercised its discretionary authority to permit a taxpayer to make a late election because it found that the taxpayer had acted reasonably and in good faith in relying on tax preparation software which the taxpayer later discovered did not adequately handle a specific tax provision.

The issue concerned the election to treat qualified dividend income as investment income under §§ 163(d)(1) and 163(d)(4)(B):

Taxpayer timely filed Form 1040, Individual Income Tax Return, for Year 1. The return was prepared using a computerized tax return preparation software program sold to the general public. Taxpayer's return included Form 4952, Investment Interest Expense Deduction. It is represented that the tax return preparation program permits a taxpayer to elect to include all of the taxpayer’s qualified dividend income in investment income. The software program does not calculate the optimal amount of qualified dividend income the taxpayer should include in investment income and does not advise the taxpayer that the software program does not calculate this optimal amount. Instead, a taxpayer using the program was required to compute this amount and manually enter it into the software program. It is represented that Taxpayer did not realize that the software program did not compute the proper amount to include in investment income and merely elected to include all qualified income in investment income on Form 4952 for Year 1.

The IRS accepted the glitch in the tax preparation software as an adequate excuse enabling the taxpayer to file a late election:

The information and representations made by Taxpayer establish that Taxpayer acted reasonably and in good faith with this request.

May 22, 2006 in IRS News | Permalink | Comments (2) | TrackBack (0)

Law Review and Tax Journal Rankings by Cites Per Cost

John P. Doyle, Associate Law Librarian at Washington & Lee, has constructed an interesting web site:  Selecting U.S. Legal Periodicals: What Cost-Effective U.S. Legal Periodicals Can Be Purchased with a Given Budget.  It evaluates over 700 law reviews on a cites per cost metric:

The Cites per Cost ranking is the average yearly number of cites to the journal divided by the annual US$ cost to U.S. academic libraries. So e.g., a journal with 600 cites per annum and costing $60 would show '10' in the Cites per Cost column.

Here are the Top 20 law reviews in the cites per cost measure:

Wl_top_10_2

Here are the Top 10 tax journals in cites per cost:

Tax Rank

Overall Rank

Tax Journal

Cost

Cites/Cost

1

411

Virginia Tax Review

$54

0.64

2

418

Tax Lawyer

$83

0.60

3

436

Akron Tax Journal

$13

0.47

4

478

Tax Law Review

$110

0.31

5

506

Florida Tax Review

$125

0.21

6

519

National Tax Journal

$155

0.17

7

522

Houston Business & Tax J.

$38

0.15

8

550

Taxes

$245

0.08

9

569

Tax Notes

$2,078

0.06

10

578

Corporate Taxation

$290

0.05

(Hat Tip:  Dan Filler.)

May 22, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Death of Paul E. Treusch

TreuschI am sorry to bring you the news of the death at age 95 of Paul E. Treusch, former Associate Chief Counsel of the the IRS and tax professor at Southwestern from 1979-2004. From the Washington Post obituary:

Mr. Treusch was born in Chicago and graduated from the University of Chicago, where he also received a law degree in the mid-1930s. After teaching at Louisiana State University, he came to Washington and joined the IRS. He was the assistant chief counsel for more than 30 years, until he retired about 1970.

During the 1970s, he taught at Howard University School of Law, Boston University School of Law and again at Howard. In 1979, he moved to Los Angeles, where he taught at Southwestern Law School for 25 years.

He developed a specialty in international tax law and published a textbook on tax-exempt organizations. Also, he was a visiting professor in Hong Kong, China and Mexico. Southwestern Law School established an annual lectureship and teaching position to honor Mr. Treusch and his wife. He retired at age 93 after suffering a stroke.

For more, see the Southwestern press release.

May 22, 2006 in Obituaries | Permalink | Comments (0) | TrackBack (0)

NLJ: Sidley Austin Faces $100 Million-Plus Liability for Tax Shelter Opinions

Interesting article in the National Law Journal:  Sidley Could Face $100M Liability in Opt-Outs; With Many Tax Case Plaintiffs Refusing to Settle, Firm's Share of Liability Costs Could Hit Nine-Figure Mark, Says Attorney, by Amanda Bronstad:

Sidley Austin is expected to pay $30 million to settle a class action next month filed by more than 200 investors who lost money on illegal tax shelters that the law firm approved. But the nation's seventh-largest firm isn't out of the woods yet. Investors in about 55 cases have opted out of the class action settlement, which includes claims against KPMG LLP, the accounting firm that sold the shelters. The shelters are now the subject of a federal criminal investigation. Lawyers representing those opt-outs say KPMG and Sidley Austin could end up paying hundreds of millions of dollars in separate settlements with their clients.

May 22, 2006 in News | Permalink | Comments (0) | TrackBack (0)

Sunday, May 21, 2006

Top 5 Tax Paper Downloads

Ssrn_logo_85There is no movement in this week's list of the Top 5 Recent Tax Paper Downloads on SSRN, with the same five papers in the same order as last week:   

1.  [271 Downloads]  Financial Accounting and Corporate Behavior, by David I. Walker (BU) [blogged here]

2.  [239 Downloads] Earnings Management and Corporate Tax Shelters, by Mihir A. Desai (Harvard Business School) & Dhammika Dharmapala (University of Connecticut, Economics) [blogged here]

3.  [145 Downloads]  Is the Tax System Beyond Reform?, by George K. Yin (Virginia)  [blogged here]

4.  [124 Downloads]  The Federal Definition of Tax Partnership, by Bradley T. Borden (Washburn) [blogged here]

5.  [106 Downloads]  Working for Free: It Ought to be Against the (Tax) Law, by Richard Winchester (Thomas Jefferson)  [blogged here]

May 21, 2006 in Top 5 Downloads | Permalink | Comments (0) | TrackBack (0)

NY Times: Despite No-Tax Pledge, Bush Increases Taxes on Teenagers

Interesting article in the Sunday New York Times:  Despite Pledge, Taxes Increase for Teenagers, by David Cay Johnston:

The $69 billion tax cut bill that President Bush signed this week tripled tax rates for teenagers with college savings funds, despite Mr. Bush's 1999 pledge to veto any tax increase.

Under the new law, teenagers age 14 to 17 with investment income will now be taxed at the same rate as their parents, not at their own rates. Long-term capital gains and dividends that had been taxed at 5% will now be taxed at 15%. Interest that had been taxed at 10 percent will now be taxed at as much as 35%....

Mr. Bush pledged in 1999 to veto any bill that raised taxes.

May 21, 2006 in News | Permalink | Comments (2) | TrackBack (1)

WSJ: Surge in Taxes Paid by Wealthy

Interesting front page article in the Weekend Wall Street Journal:  Their Income Up, U.S. Rich Yield A Tax Windfall; Surging Receipts Prompt Lower Deficit Projections, Debate Over Bush Tax Cuts, by Deborah Solomon:

Top_10_5As America's rich get richer, the taxes they pay on their increasing income is yielding a windfall for the U.S. Treasury. The Bush administration and its supporters point to a recent surge in tax receipts as vindication of the 2001 and 2003 tax cuts that critics say favored the wealthy. And even opponents of the tax cuts acknowledge that the surge in unanticipated revenue is coming from the rich.

With wealthy Americans taking an increasing share of total household income and paying a greater share of total taxes, "what we're seeing is a repeat of the late '90s, where you get a flood of tax revenues from the hyper-rich," said Rudolph Penner, a former Congressional Budget Office director now at the Urban Institute think tank. "It may raise some worries socially, but it certainly is good for revenue."

The Treasury reported last week that tax receipts in April jumped 13.5% from a year earlier to $315.1 billion -- much of that increase coming from taxes on investments and other sources of income more important to the wealthy. Receipts from these so-called nonwithheld taxes in April, a month when many tax returns are filed, were up about 17% from a year earlier. (Most Americans have the bulk of their taxes withheld from wages paid through the year.)

May 21, 2006 in News | Permalink | Comments (1) | TrackBack (0)

Crane on The Income Tax and the Burden of Perfection

Crane_1 Charlotte Crane (Northwestern) has published The Income Tax and the Burden of Perfection, 100 Nw. U. L. Rev. 171 (2006).  Here is the concluding paragraph:

Does all of this mean that the income tax should be abandoned? No. The solution lies not in throwing out the instrument, but instead in admitting that, although the income tax can be administered more rationally than other taxes, it simply is not worth the cost of striving for perfection. The gap between the concept of income--so heavily relied upon to justify the tax--and the realities of the actual tax instrument we have developed has always been there. Practical observers have always urged others to simply calm down and accept the disparity between concept and reality.

May 21, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Saturday, May 20, 2006

Oswald on The Reliability of Prestigious Scholarly Journals

Oswald Ssrn_77 Andrew J. Oswald (University of Warwick) has posted An Examination of the Reliability of Prestigious Scholarly Journals: Evidence and Implications for Decision-Makers on SSRN.  Here is the abstract:

In universities all over the world, hiring and promotion committees regularly hear the argument: this is important work because it is about to appear in prestigious journal X. Moreover, those who allocate levels of research funding, such as in the multi-billion pound Research Assessment Exercise in UK universities, often come under pressure to assess research quality in a mechanical way by using journal prestige ratings. The results in this paper suggest that such tendencies are dangerous. It uses total citations over a quarter of a century as the criterion. The paper finds that it is far better to publish the best article in an issue of a medium-quality journal like the Oxford Bulletin of Economics and Statistics than to publish the worst article (or often the worst 4 articles) in an issue of a top journal like the American Economic Review. Implications are discussed.

May 20, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

SOI Releases Possessions Corporations 2003

Irs_logo_188The Statistics of Income Division has released Tax Stats 2006-14:  Possessions Corporations 2003:

Two tables are now available containing Tax Year 2003 statistics for possessions corporations, including statistics that focus specifically on balance sheet items, income statement items, and distributions to stockholders, by selected industry.

May 20, 2006 in IRS News | Permalink | Comments (0) | TrackBack (0)

NAACP Releases Documents Detailing Republican Requests for Audit of Civil Rights Group

Irs_logo_251 NaacpWe previously have blogged Fran Hill's article, Auditing the NAACP: Misadventures in Tax Administration, which argues that "the IRS's probe of the NAACP to determine whether the civil rights group engaged in partisan politics in violation of § 501(c)(3) has created a controversy that promises to end badly for just about everybody."  In the latest chapter of the story, the NAACP has released 523 pages of documents it has obtained pursuant to a FOIA request detailing requests by Congressional Republicans that the IRS investigate the civil rights group.  The NAACP also has announced that it has asked the Treasury Inspector General for Tax Administration to review the IRS’s handling of the FOIA request.

For press coverage, see:

May 20, 2006 in Political News | Permalink | Comments (0) | TrackBack (0)

Spotlight_1_1David M. Hasen (Michigan)

        • B.A. 1984, Reed College
        • Ph.D. 1993. Harvard
        • J.D. 1996, Yale

   

      

Hasen_1

I am one of those people who “fell” into tax law. After college I entered a Ph.D. program in political science, planning for a teaching career. My main interest was political theory. By the time I completed the program, however, there were few teaching jobs, and prospects in political science seemed dim. I therefore took what seemed like the default option and went to law school. At the time I was considering both a law teaching career and law practice.

I took the introductory federal income tax course as a 2L, but only because I believed that a basic knowledge of tax law was important for a lawyer starting out; it was not a course that I thought I would enjoy. In fact I was pretty anxious about it. I was not at all sure I would be able to deal with all the numbers I expected or to navigate the dense Code language that, as one of my classmates once noted, “never seems to get past the optic nerve.”

Continue reading

May 20, 2006 in Tax Prof Spotlight | Permalink | Comments (0) | TrackBack (0)

Bartlett on Tax Policy and Immigration

Bartlett_3Interesting op-ed in the Wall Street Journal:  The Illegal Immigrant Tax Payer, by Bruce Bartlett:

As the problem of illegal immigration becomes more heated, the experiences of the states provide lessons on how it can be minimized. Tax policy is one area where governments can help reduce the burden of illegal immigration.

Illegal aliens are almost by definition members of the underground economy . . . .

This being the case, one cannot realistically tax them the way citizens are taxed. Workers in the underground economy are usually paid cash off the books. Such wages are unreported to the tax authorities and those receiving them are highly unlikely to file income tax returns. Therefore, the income tax is never going to raise much revenue from illegal aliens. Steve Camarota of the Center for Immigration Studies estimates that illegal-alien households pay only 20% as much income tax as non-illegal immigrant households....

Payroll taxes have broader coverage because there are no exemptions or offsets. So it is not surprising that illegal aliens pay more of these—about 40% of what citizens and legal aliens pay.However, when it comes to federal excise taxes, such as those for gasoline or tobacco, illegal aliens pay close to the same amount of tax as the rest of us. Mr. Camarota estimates that they pay 70% as much of such taxes as all households do....

[I]t is reasonable to assume that when it comes to state taxes, the same sort of pattern holds. Illegal aliens probably pay very little state income taxes, but close to their share of sales taxes. Therefore, states that rely more heavily on sales taxes than income taxes are going to get more revenue out of their illegal aliens to pay for the expenses they incur. This helps explain why California is burdened much more by illegal aliens than Texas....

Liberals always condemn sales taxes as regressive—taking more in percentage terms from the poor than the rich. However, realistically, such taxes are the only ones that really get revenue from the illegal-alien population to offset the large and growing cost they impose for health care, education and other government services.

For more on tax policy and immigration, see Francine J. Lipman, Taxing Undocumented Immigrants: Separate, Unequal and Without Representation, 59 Tax Law. ___ (2006).

May 20, 2006 in News | Permalink | Comments (0) | TrackBack (0)

McLaughlin Wins Teacher of the Year Award at Utah

Mclaughlin_2 Congratulations to Tax Prof Nancy A. McLaughlin, who was presented with the 2006 Peter W. Billings Excellence in Teaching Award at the commencement ceremony honoring the graduates of the University of Utah S.J. Quinney College of Law:

The Excellence in Teaching Award is given annually to a particularly dedicated, gifted, and enthusiastic professor who is known for inspiring his or her students.

Nancy teaches federal income tax, estate planning, trusts and estates, and private land conservation.

May 20, 2006 in Tax Profs, Teaching | Permalink | Comments (0) | TrackBack (0)

Sitkoff on The Lurking Rule Against Accumulations of Income

SitkoffRobert H. Sitkoff (NYU) has published The Lurking Rule Against Accumulations of Income, 100 Nw. U. L. Rev. 501 (2006).  Here is the abstract:

For 200 years the rule against accumulations of income, which limits the time during which a settlor may direct the trustee to accumulate and retain income in trust, has lurked in the shadow of its older and more distinguished cousin, the Rule Against Perpetuities. With the erosion of the Rule Against Perpetuities, however, the rule against accumulations may have newfound relevance. Perpetual trusts are more likely than ordinary trusts to involve accumulations of income, and such trusts are designed to endure beyond the permissible common law accumulations period. This essay examines the relevance of the rule against accumulations for the rise of the perpetual trust. The essay also assesses the contemporary policy soundness of the accumulations rule.

May 20, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Friday, May 19, 2006

NYSBA Tax Section on Notice 2005-74

Nysba_logoThe New York State Bar Association Tax Section on Wednesday submitted a letter and report to the Treasury Department and IRS on Notice 2005-74 concerning the effect of common asset reorganizations on gain recognition agreements. 

 

May 19, 2006 in NYSBA Tax Section | Permalink | Comments (0) | TrackBack (0)

Levy Economics Institute Hosts Conference on Gender Equality, Tax Policies, and Tax Reform in Comparative Perspective

Levy_institute_1 The Levy Economics Institute at Bard College hosted a two-day conference this week on Gender Equality, Tax Policies, and Tax Reform in Comparative Perspective, with sessions on:

  • Modeling the Implications of Personal Income Tax for Intra-Household Inequality and Labor Market Participation in Europe
  • Gender Dimensions of Tax Reform in Europe
  • Gender-Blind and Gender-Aware Tax Policy
  • Personal Income Tax in Bargaining Models
  • Taxation and Marriage in the USA
  • Gender, Taxation, and Development
  • Gender and Taxation in Africa
  • Gender and Tax Policy Advocacy

Here are the U.S. Tax Profs who presented papers:

For a list of all presenters and the titles of their papers, as well as all discussants, see here.  Bridget offers her perspective on the conference at Feminist Law Professors.

May 19, 2006 in Tax Conferences | Permalink | Comments (0) | TrackBack (0)

Cohen & Sager on Why Civil Rights Lawyers Should Study Tax

Ssrn_76Stephen B. Cohen (Georgetown) & Laura Sager (NYU) have posted Why Civil Rights Lawyers Should Study Tax, 22 Harv. Blackletter L.J. ___ (2006) on SSRN.  Here is the abstract:

Civil rights and income taxation may seem as far apart as any two legal subjects could be, but actually intersect in a surprising number of significant ways. Whenever money damages are sought in civil rights litigation, the tax treatment of damages will affect the amount that actually benefits the plaintiff after taxes. Even when litigation seeks non-money damages, as in predatory lending cases, civil rights lawyers need to attempt to structure the relief so that it does not cause undesirable tax consequences, such as income arising from forgiveness of debt. Civil rights lawyers may also need to analyze the financial consequences of tax benefits, such as tax-exempt status, in order to ascertain whether such benefits raise issues under the First Amendment’s Establishment Clause and the Fourteenth Amendment’s Equal Protection Clause. This essay discusses the intersection of civil rights law and income taxation in the three areas mentioned above: damages for unlawful discrimination, the forgiveness of debt by a predatory lender, and tax-exempt status for private educational and religious institutions. We conclude that civil rights lawyers need to be aware of potential tax implications of civil rights litigation to a surprising degree.

May 19, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Leviner Selected for Chancellor's List

LevinerChancellors_list_1 Congratulations to Sagit Leviner, an SJD candidate at Michigan with a tax concentration:  she has been selected for the second year to appear in The Chancellor's List, which honors the Top 1% of graduate students in the United States from 3000 colleges and universities:

Being selected for nomination to The Chancellor's List is an honor bestowed on outstanding college graduate students by the professors and teachers who know their work best. Because of the enthusiastic cooperation of these educators, The Chancellor's List has already become the largest recognition publication in the nation honoring exceptional college graduate students.

May 19, 2006 in Tax Profs | Permalink | Comments (0) | TrackBack (0)

Kwall on Subchapter G: Crusade Without a Cause?

Ssrn_logo_140 Kwall_2 Jeffrey L. Kwall (Loyola-Chicago) has posted Subchapter G of the Internal Revenue Code: Crusade Without a Cause?, 5 Va. Tax Rev. 223 (1985), on SSRN.  Here is the abstract:

This Article begins by tracing the evolution of the accumulated earnings tax and the personal holding company tax from their origins to the mid-1980s. The Article then demonstrates the limited extent to which these corporate penalty taxes serve their historical purpose of preventing taxpayers from enjoying significant tax savings through the use of the corporate form. Finally, the Article addresses whether the accumulated earnings tax and the personal holding company tax are appropriate and efficient mechanisms for inducing corporations to distribute their earnings when individual tax rates do not greatly exceed corporate tax rates.

May 19, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

NTA Hosts 4th State-Local Program on Implications of Rising Residential Property Values for the Property Tax

The National Tax Association 4th State-Local Program on Implications of Rising Residential Property Values for the Property Tax.  Here are today's scheduled panels, speakers, and topics:

1:30 - 3:00 p.m.The Property Tax Environment

  • Real Estate Market Review: Is There a Residential Bubble and Will it Pop?
    • View 1: Richard K. Green (George Washington)
    • View 2: Todd Sinai (Wharton School)
  • The Property Tax Bound: A Review of Constraints
    • Therese McGuire (Northwestern)
    • J. Fred Giertz (Illinois-Champagne)
    • Nathan Anderson (Illinois-Chicago)

3:15 - 4:30 p.m.:  State Responses and Impacts:

  • Illinois:
    • Richard Dye (Lake Forest & Illinois-Chicago)
    • Daniel McMillen (Illinois-Champaign)
    • David Merriman (Loyola-Chicago & Illinois-Chicago)
  • New Jersey:
    • Ranjana Madhusudhan (New Jersey Department of the Treasury)
  • Washington, D.C. Metro:  John H. Bowman (Virginia Commonwealth)
  • Utah:  Gary Cornia & Larry Walters (both of BYU)

4:30 - 4:55 p.m. Roundtable Discussion

The conference is being held at the Holiday Inn Capitol, 550 C Street, S.W. (L΄Enfant Plaza Metro), Washington, D.C.  20024.

May 19, 2006 in Tax Conferences | Permalink | Comments (0) | TrackBack (0)

Accountants' Association Loses Social Security Numbers of its Members

The American Institute of Certified Public Accountants (AICPA), the professional association of CPAs, has sheepishly announced that it has lost a computer file containing the names, addresses, and social security numbers of some its members:Aicpa_letter_page_1_1 

(Hat Tip:  Michael Gould.)  For further discussion, see:

May 19, 2006 in News | Permalink | Comments (2) | TrackBack (2)

Perry on The Relative Value of American Law Reviews

Perry_1 Ssrn_logo_87Ronen Perry (University of Haifa, Faculty of Law; Israeli Private Law Forum) has posted The Relative Value of American Law Reviews: Refinement and Implementation on SSRN.  Here is the abstract:

This Essay complements a recently published article in which I discussed the theoretical and methodological aspects of law review rankings. The Relative Value of American Law Reviews: A Critical Appraisal of Ranking Methods, 11 Va. J. L. & Tech. ___ (2006) [blogged here].

The purpose of this Essay is twofold: Refinement of the theoretical framework, and implementation. It proposes, defends, and implements a complex ranking method for general-interest student-edited law reviews, based on a judicious weighting of normalized citation frequency and normalized impact factor. It then analyzes the distribution of journals' scores, and the diminishing marginal difference between them. Finally, it examines the correlation between law schools' positions in the U.S. News & World Report latest ranking and their flagship law reviews' positions under the proposed method, and between these schools' overall scores and their law reviews' final scores.

Here is Ronen's ranking of the Top 40 American law reviews:

Top_40_1 

May 19, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Thursday, May 18, 2006

NTA Hosts 36th Spring Symposium Today on Big Ideas -- The Morning After

The National Tax Association concludes its two-day 36th Spring Symposium today on Big Ideas -- The Morning After.  Here are today's scheduled panels, speakers, and topics:

9:00 a.m. - 10:30 a.m.A Multi-Disciplinary Discussion of the Domestic Manufacturing Deduction

  • Moderator: James Mackie (Office of Tax Analysis, U.S. Treasury Department)
  • Papers:
    • John McClelland (Office of Tax Analysis, U.S. Treasury Department) − Five Things an Economist Thinks are Important in Analyzing the Domestic Manufacturing Deduction
    • Lillian F. Mills (Arizona) − Five Things an Accountant Thinks are Important in Analyzing the Domestic Manufacturing Deduction
    • Clarissa Potter (Office of the Chief Counsel, IRS) − Five Things an Attorney Thinks are Important in Analyzing the Domestic Manufacturing Deduction
    • George Plesko (Connecticut) − Interdisciplinary Issues in Tax

10:45 a.m. - 12:15 p.m.Collective Impacts of Piecemeal Tax Policies − The Devil’s in the Details

  • Organizer/Moderator: Nicholas Bull (Joint Committee on Taxation)
  • Papers:
    • Paul Burnham & Larry Ozanne (both of the Congressional Budget Office) − Distortions from Piecemeal Tax Reform Revealed Through Effective Tax Rates
    • Jane Gravelle (Congressional Research Service) & Jennifer Gravelle (Government Accountability Office) − Horizontal Equity and Family Tax Treatment: The Orphan Child of Tax Policy
    • Michael Cooper & Mathew Knittel (both of the Office of Tax Analysis, U.S. Treasury Department) − Partial Refundability: How are Corporate Tax Losses Used?
  • Discussants:
    • Eric Toder (The Urban Institute)
    • Paul Menchik (Michigan State)
    • Drew Lyon (PricewaterhouseCoopers)

The conference is being held at the Holiday Inn Capitol, 550 C Street, S.W. (L΄Enfant Plaza Metro), Washington, D.C. 20024

May 18, 2006 in Tax Conferences | Permalink | Comments (0) | TrackBack (0)

NY Times: Technology Increasing Student Cheating

Interesting article in the New York Times:  Colleges Chase as Cheats Shift to Higher Tech, by Jonathan D. Glater:

With their arsenal of electronic gadgets, students these days find it easier to cheat. And so, faced with an array of inventive techniques in recent years, college officials find themselves in a new game of cat and mouse, trying to outwit would-be cheats this exam season with a range of strategies — cutting off Internet access from laptops, demanding the surrender of cellphones before tests or simply requiring that exams be taken the old-fashioned way, with pens and paper.

In a survey of nearly 62,000 undergraduates on 96 campuses over the past four years, two-thirds of the students admitted to cheating. The survey was conducted by Don McCabe, a Rutgers professor who has studied academic misconduct and helped found the Center for Academic Integrity at Duke.

May 18, 2006 in Law School | Permalink | Comments (0) | TrackBack (0)

Luja Appointed Professor of Comparative Tax Law at Maastricht University

LujaRaymond Luja has been appointed Professor of Comparative Tax Law at Maastricht University:

Professor Luja has taught several tax law courses at Maastricht University since 1998. He is an expert in fiscal state aid issues and he is the author of ‘Assessment and Recovery of Tax Incentives in the EC and the WTO: a View on State Aids, Trade Subsidies and Direct Taxation’. He will among other be responsible for extending the English-language track of the Maastricht LL.M programme in International Tax Law. He is also a visiting lecturer at the International Tax Center Leiden and the International Tax Academy of the International Bureau of Fiscal Documentation. Furthermore he is affiliated with the EU Tax Law Group of Loyens & Loeff, Amsterdam.

(Hat Tip:  Tax Grotto.)

May 18, 2006 in Tax Prof Moves | Permalink | Comments (0) | TrackBack (0)

Daily Show with Jon Stewart Skewers Tax Bill

Daily_show_3The Daily Show with Jon Stewart last night skewered the Tax Increase Prevention and Reconciliation Act of 2005 signed by the President yesterday in this segment (Bush's Tax Cuts) by Dan Bakkedahl.

May 18, 2006 in Celebrity Tax Lore | Permalink | Comments (0) | TrackBack (0)

Tax Court Denies Conservation Easement Deduction

Tax_court_31The full Tax Court decided an important conservation easement case on Tuesday, Turner v. Commissioner, 126 T.C. No. 16 (5/16/06):

P, a real estate investor, purchased 29.3 acres of unimproved land in a historical overlay district, 15.04 acres of which were located within a designated floodplain. Property development was subject to county regulations that were more stringent for property within a historical overlay district. Among the regulations were zoning and rezoning requirements, as well as limitations on development of designated floodplain areas. Thirty lots were permissible under current zoning. County approval would be required for denser zoning usage. P, claiming that he was entitled to develop up to 62 residences on smaller lots, executed a deed to Fairfax County purporting to limit development of the property to 30 residences. On their 1999 Federal income tax return, Ps claimed a contribution deduction for a qualified conservation easement under § 170(h)(1).

1. Held: P did not make a contribution of a qualified conservation easement under § 170(h)(1) because the attempted grant did not satisfy the conservation purposes required under § 170(h)(4)(A). Specifically, the deed did not preserve open space or a historically important land area or certified historical structure.

2. Held, further, Ps are liable for a 20% penalty for negligence under § 6662.

(Hat Tip:  Nancy McLaughlin.)

May 18, 2006 in New Cases | Permalink | Comments (0) | TrackBack (0)

British Taxman Beats André Agassi in Final Set

Inland_revenue_1 AgassiWe previously have blogged (here) André Agassi's tax claim against British tax authoriities.  The case has broad implications for athletes and entertainers performing in the UK.

The House of Lords (the UK's highest court) has ruled in Agassi v. Robinson, 2006 UKHL 23 (5/17/06), that foreign athletes and other entertainers working in the UK are subject to UK income tax on sponsorship revenue received in connection with their UK activities.  The ruling reversed a lower court ruling which held that Agassi's controlled US company, Agassi Enterprises, was not subject to UK income tax on sponsorship revenue received from Nike and Head while playing in UK tennis tournaments.   For press coverage, see:

For all of the Agassi v. Robinson opinions, see:

May 18, 2006 in Celebrity Tax Lore, New Cases | Permalink | Comments (0) | TrackBack (0)

Cooper on Interstate Competition and State Death Taxes

Ssrn_logo_139Cooper Jeffrey A. Cooper (Cummings & Lockwood, Stamford, CT) has posted Interstate Competition and State Death Taxes: A Modern Crisis in Historical Perspective, 33 Pepperdine L. Rev. ___ (2006), on SSRN.  Here is the abstract:

State death taxes are one of the oldest forms of state revenue, dating back to the early 19th century. Yet, as the 21st century begins, these taxes face a significant crisis. In just the past five years, prompted by the 2001 repeal of the federal “state death tax credit” that had facilitated collection of these taxes, and yielding to increasingly vocal anti-tax rhetoric, half of the states simply have abandoned this form of tax revenue. This dramatic shift in state tax policy impacts not only the states that have repealed death taxes, but also those that still impose these taxes. The former now must find alternate forms of revenue or reduce governmental expenditures. The latter now must fear that taxpayers will “vote with their feet,” abandoning the states that impose death taxes towards the growing number of states touting their more favorable tax climates. As interstate competition to attract these wealthy migrants intensifies, at stake is far more than the mere billions of dollars of state revenue generated by death taxes. Rather, the crisis implicates the fundamental nature of modern state taxation, raising the question of whether traditionally progressive forms of state taxation can survive in an increasingly mobile society.

Continue reading

May 18, 2006 in Scholarship | Permalink | Comments (0) | TrackBack (0)

Iowa Law Students Protest Professor's Use of Racial Slur

Iowa_1 Interesting article in this morning's Des Moines Register:  Racial Slur Read by Professor Upsets U of I Law Students; Professor Says Racial Term Fit in a Negotiations Class, by Erin Jordan:

A professor's use of readings containing racial slurs has alarmed students and renewed discussions about diversity at the University of Iowa law school....

The university's Black Law Students Association, a group of 27 students, said in a letter to law faculty, U of I administration and the Iowa Board of Regents executive director that a March 29 incident was "indicative of a much larger problem at the College of Law."

The incident that triggered the larger discussion was professor Gerald Wetlaufer reading aloud two passages that contained racial epithets in his negotiations class, according to law school Dean [and Tax Prof] Carolyn Jones.

Continue reading

May 18, 2006 in Law School | Permalink | Comments (2) | TrackBack (2)

What Would Jesus Tax?

Bible_1We previously have blogged Susan Pace Hamill's scholarship on the application of Christian principles to tax policy:

Susan recently has published several op-eds on the subject:

Susan's colleague Dan Filler notes:

Susan and I probably disagree on many things but her passion and commitment are incredible, and her emphasis on religious claims to shape tax policy debates is brilliant. The Economist captured her campaign in support of Alabama tax reform with the headline "What Would Jesus Tax?" Democrats may be able to retake the White House without fully engaging policy debates within a genuinely religious framework. But they won't win states like Alabama. And that will leave Democrats perpetually vulnerable.

I don't know where Susan stands, party-wise, but she is providing an important roadmap for a national progressive strategy. Not bad for a tax jock. Not bad at all.

For further TaxProf Blog coverage, see:

May 18, 2006 in Scholarship | Permalink | Comments (2) | TrackBack (0)