Volume 64, No. 3 - Spring 2011

Articles

Taxation

Circular Cash Flows and the Federal Income Tax

Jasper L. Cummings, Jr.

This Article investigates the suspicion exhibited by the federal judiciary and the Service toward circular flows of cash and other property. The courts and Service suspect that nothing happened for tax purposes...

Taxation

Risk, Ownership, Equity: 2011 Erwin N. Griswold Lecture

Charles I. Kingson

In John Ford’s They Were Expendable, sailors at a Manila bar in December 1941 wait for Boats (played by Ward Bond) to toast Doc’s retirement. They even turn down the radio (missing news of Pearl Harbor) to hear him. ...

Taxation

A Riff on Cliff: Calloway and Anschutz Expand Tax Ownership Authorities from Debt to Equities

Mark Leeds

When I was starting out as a tax lawyer many years ago, I was greatly impressed by Walter Cliff and Philip Levine’s 1985 article entitled, Reflections on Ownership Sales and Pledges of Installment Obligations. ...

Comments

Taxation

The Statute of Limitations for the TEFRA Partnership Proceedings: The Interplay Between Section 6229 and Section 6501

Anisa Afshar

The Tax Equity and Fiscal Responsibility Act of 1982 (TEFRA) created the unified audit and litigation proceedings for partnerships (the TEFRA Partnership Proceedings), adding sections 6221 through 6233 to the Code. ...

Taxation

The Low-Income Tax Gap: The Hybrid Nature of the Earned Income Tax Credit Leads to Its Exclusion from Due Process Protection

Megan Newman

Sandra Booker lives in southeast Washington, D.C., with her three children. She earns $20,000 per year as a receptionist and has lived in the same rented apartment for 20 years. This year she spent a month in the hospital...

Notes

Taxation

Something Rotten in the Netherlands: The Case of X and Passenheim-van Schoot and the Demise of EU Taxpayer Rights Under the EU Treaty

Danielle Gill

Today’s borderless economic world allows both taxpayers and capital unprecedented mobility. However, while the mobility of capital and persons knows few bounds, state power remains confined to each state’s own territory. ...

Taxation

Recognizing Roth IRAs as S Corporation Shareholders: A Critique of Taproot v. Commissioner

Shannon Tucker

Individuals planning for retirement often set up a Roth Individual Retirement Account (Roth IRA) to manage savings and take advantage of government-provided tax benefits. ...

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Vol. 64, No. 3 - Spring 2011

The Tax Lawyer, Spring 2011

Articles

Circular Cash Flows and the Federal Income Tax

Risk, Ownership, Equity: 2011 Erwin N. Griswold Lecture

A Riff on Cliff: Calloway and Anschutz Expand Tax Ownership Authorities from Debt to Equities

Comments

The Statute of Limitations for the TEFRA Partnership Proceedings: The Interplay Between Section 6229 and Section 6501

The Low-Income Tax Gap: The Hybrid Nature of the Earned Income Tax Credit Leads to Its Exclusion from Due Process Protection

Notes

Something Rotten in the Netherlands: The Case of X and Passenheim-van Schoot and the Demise of EU Taxpayer Rights Under the EU Treaty

Recognizing Roth IRAs as S Corporation Shareholders: A Critique of Taproot v. Commissioner

The Tax Lawyer

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Renew Your ABA Membership

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Vol. 64, No. 3 - Spring 2011

The Tax Lawyer, Spring 2011

Articles

Circular Cash Flows and the Federal Income Tax

Risk, Ownership, Equity: 2011 Erwin N. Griswold Lecture

A Riff on Cliff: Calloway and Anschutz Expand Tax Ownership Authorities from Debt to Equities

Comments

The Statute of Limitations for the TEFRA Partnership Proceedings: The Interplay Between Section 6229 and Section 6501

The Low-Income Tax Gap: The Hybrid Nature of the Earned Income Tax Credit Leads to Its Exclusion from Due Process Protection

Notes

Something Rotten in the Netherlands: The Case of X and Passenheim-van Schoot and the Demise of EU Taxpayer Rights Under the EU Treaty

Recognizing Roth IRAs as S Corporation Shareholders: A Critique of Taproot v. Commissioner

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect