Vol. 41 No. 2 - Winter-Spring 2022

Taxation

The Federal Tax System’s Administrative Law Woes Grow

Kristin E. Hickman

Recent court decisions have substantial implications for litigation over past tax regulatory actions and for future tax administrative practices including Hewitt v. Comm'r, Oakbrook Land Holdings, LLC v. Comm'r, and others.

Taxation

The U.S. Tax Court’s Promotion of Civility

William Schmidt

This article discusses how practices like stipulations encourage cooperation and minimize the need for discovery in the U.S. Tax Court, with those practices maintained by the Tax Court, the IRS and others involved with the Tax Court.

Taxation

Liquidations and C Reorganizations Through the Prism of the IRS 2021 Audit of Bausch Health’s 2017 Granite Trust Transaction

Joshua A. Lesser

This article discusses the legal and regulatory framework of recognition vs. nonrecognition liquidations and reorganizations through an IRS Notice of Proposed Adjustment disallowing a 2017 capital loss reported by Bausch Health Companies Inc.

Taxation

The First-Time Abatement Policy—Harsh Realities and Strategic Considerations

Garrett L. Brodeur

The IRS’s first-time abatement policy waives tax penalties under certain circumstances but can occasionally lead to unfair results. A recent decision illustrates the harsh realities of the policy and offers tips for taxpayers requesting FTA relief.

Taxation

The Intersection of Pro Bono Counsel and Amici Curiae

Andrew R. Roberson

Since Tax Court opinions are applied to taxpayers throughout the country, it is important that cases involving common issues are adequately briefed and presented to the Court. Pro bono counsel and amici curiae are working hard to address this issue.

Taxation

Recipient of the 2022 Janet Spragens Pro Bono Award: Karen Lapekas

On May 14, 2022, at the ABA Tax Section’s Hybrid May Tax Meeting, the Section awarded the 2022 Janet Spragens Pro Bono Award to Karen Lapekas. This award, established in 2002, recognizes individuals or law firms for their outstanding...

Taxation

2022 Distinguished Service Award Recipient: Karen L. Hawkins

Paula M. Junghans

The Distinguished Service Award is the highest honor awarded by the Section of Taxation of the American Bar Association. The award is given to individuals who have had a distinguished career in taxation and who have provided an aspirational...

Taxation

Winners of the 21st Annual Law Student Tax Challenge

The Section is pleased to announce the winners of the 21st Annual Law Student Tax Challenge, a contest designed to give students an opportunity to research, write about, and present their analyses of a real-life tax planning problem. ...

Taxation

In Memory of Bob Pope

Kenneth C. Weil

Members of the ABA Tax Section and the tax community at large remember William Robert (Bob) Pope, Jr., a leader in the Section's Tax Collections, Bankruptcy and Workouts committee.

Taxation

Tax Section Relaunches People in Tax Podcast

This spring, the Tax Section is relaunching its People in Tax Podcast. The podcast features interviews exploring the stories and careers of ABA Tax Section members, government officials, and others who influence, work in, or study tax law and policy.

Taxation

Guys and Gals With Carried Interest (Not capital gains)

Robert S. Steinberg

To the tune of The Girl from Ipanema by Antonio Carlos Jobim, Vinicius de Moraes, and Norman Gimble, as recorded in 1964 by Stan Getz & Astrud Gilberto and in 1963 in Portuguese by João Gilberto & Stan Getz.

Taxation

We Must Raise Taxes on the Rich—A Critical Review of Tax the Rich! and the Patriotic Millionaires

Michael Conklin

A book review of Tax the Rich!: How Lies, Loopholes, and Lobbyists Make the Rich Even Richer, by Morris Pearl, Erica Payne, and The Patriotic Millionaires.

Taxation

Tax Section Publishes New Edition of Tax Evidence Book

This winter, the ABA Tax Section published the third edition of A Practitioner’s Guide to Tax Evidence, by Joni Larson. The book provides a primer to practitioners preparing for a trial before the U.S. Tax Court...

Taxation

Tax Section Publishes New Edition of Innocent Spouse Relief Guide

This spring, the ABA Tax Section is publishing the third edition of A Practitioner’s Guide to Innocent Spouse Relief, by Christine S. Speidel and Audrey Patten. The book takes the reader step-by-step through the innocent spouse claim process...

Taxation

Tax Section Publishes Tax Issues for Immigrants

This spring, the ABA Tax Section is publishing the new book Tax Issues for Immigrants: A Practical Guide to Understanding Tax Law for Immigrant Taxpayers, by Sarah Lora, Robert G. Nassau, and Sam Rock. The book introduces the reader to the basics...

Taxation

Report of the Nominating Committee: 2022-2023 Nominees

In accordance with Sections 4.2, 6.1, and 6.3 of the Section of Taxation Bylaws, the following nominations have been submitted by the Nominating Committee for terms beginning at the conclusion of the 2022 Annual Meeting in August. ...

Taxation

2022–2024 Christine A. Brunswick Public Service Fellow

The ABA Section of Taxation is pleased to announce the 2022-2024 Christine A. Brunswick Public Service Fellowship recipient.

Taxation

2022–2023 John S. Nolan Fellowships

Named for the late Jack Nolan, a dedicated and respected ABA Section of Taxation member, the Nolan Fellow distinction is awarded to young lawyers who are actively involved in the Section and have shown leadership qualities.

Taxation

Give Back: Volunteer as a Mentor

Apply as a mentor for the inaugural class of Argrett Fellows. The Fellowship is a three-year program open to any individual with a diverse background and/or a demonstrated commitment to promoting diversity, equity, and inclusion in the tax bar.

Taxation

Government Submissions Boxscore

Government submissions are a key component of the Section's government relations activities. The full archive is available to the public on our website.

Taxation

Get Social

Stay up-to-date on the latest tax news and Section updates and events. Follow us on Twitter, LinkedIn, or Facebook. Share our recent posts with your networks and tag us in your updates!

Taxation

Virtual 2022 Midyear Tax Meeting Materials Now Available

Did you know that ABA Section of Taxation members have access to thousands of pages of cutting-edge committee program materials presented at Section meetings?

Taxation

The Tax Lawyer—Winter and Spring 2022 Issues Now Available

The Tax Lawyer, the nation's premier tax law journal, is published quarterly as a service to members of the ABA Section of Taxation.

Taxation

The Practical Tax Lawyer—March and May 2022 Issues Now Available

Produced in cooperation with the ABA Section of Taxation and published by ALI-CLE, The Practical Tax Lawyer offers concise, practice-oriented articles to assist lawyers with all aspects of tax law.

Taxation

Help Create a More Just, Equitable, Inclusive, and Diverse Tax Section with a Contribution to the JDEI Fund

Donate to the recently launched JDEI Endowment Fund which provides funding for the Loretta Collins Argrett Fellowships and Tax Section efforts to create a more diverse tax bar. ...

Taxation

Support the Section’s Public Service Efforts with a Contribution to the TAPS Endowment

Through the Tax Assistance Public Service (TAPS) endowment fund, the Section of Taxation seeks to provide stable, long-term funding for its tax-related public service programs.

Taxation

Get Involved in ATT

ABA Tax Times (ATT) is looking for volunteers to join its ranks as associate editors to assist in writing and acquiring articles for publication.

Taxation

Section CLE Products

Listen at your convenience to high-quality tax law CLE on a variety of tax topics. Here are the latest.

Taxation

Sponsorship Opportunities

Opportunities are available to enhance your visibility, grow your network, and expand your reach at ABA Section of Taxation meetings.

Taxation

Virtual 2022 Midyear Tax Meeting Sponsors

ABA Section of Taxation

Thank You To Our Virtual 2022 Midyear Tax Meeting Sponsors!

Taxation

Virtual 2022 ABA/IPT Advanced Tax Seminars Sponsors

ABA Section of Taxation

Thank You To Our Virtual 2022 ABA/IPT Advanced Tax Seminars Sponsors!

Taxation

Virtual 22nd Annual U.S. and Europe Tax Practice Trends Conference Sponsors

ABA Section of Taxation

Thank You To Our Virtual 22nd Annual U.S. and Europe Tax Practice Trends Conference Sponsors!

Taxation

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ABA Section of Taxation

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