The Tax Lawyer Winter 2011

The Tax Lawyer

Vol. 64, No. 2 - WINTER 2011

Articles

Section Members Only

The Liability-Offset Theory of Peracchi Bradley T. Borden and Douglas L. Longhofer	Full Article
The Taxation of a Gift or Inheritance from an Employer Douglas A. Kahn	Full Article
Tax Opinion Practice Robert P. Rothman	Full Article
The Submerged Logic of “Doing Business” and Attribution: Diving Below the Surface of the Offshore Lending “GLAM” Andrew Walker	Full Article

Notes

Why Common Law Calculus Failed: An Analysis of the Economic Substance Doctrine in Klamath Strategic Investment Fund v. United States Brea E. L’Heureux	Full Article
United States v. Fletcher: Through the Lens of Section 83 Applied to Restricted Stock Accounts Joseph McClain	Full Article
A (Federal) Civil Action: When the Tax Injunction Act and Comity Bar Federal Court Jurisdiction Michael Pih	Full Article
The Tax Practitioner–Client Privilege: Valero’s Shortcomings and a Better Approach John O. Sawyko	Full Article

Section members may also view this issue of The Tax Lawyer in its entirety.

If you are an ABA member, you can receive The Tax Lawyer and the Section NewsQuarterly, (both quarterly publications) when you join the Section of Taxation. Anyone can subscribe to The Tax Lawyer by contacting the ABA Service Center.

Back to TTL Home Page

Published by
Section of Taxation,
American Bar Association
in Collaboration with the
Georgetown University Law Center