Volume 71, No. 1 - Fall 2017

Articles

Taxation

A Practitioner's Guide to Tax Evidence (2d ed. 2017): A Preview

Joni Larson

The American Bar Association Tax Section has recently published the second edition of A Practitioner’s Guide to Tax Evidence. This Article provides updates discussed in the Guide and an excerpt from the Guide. ...

Taxation

Boundaries of the Prediction Model in Tax Law’s Substantial Authority

Bradley T. Borden & Sang Hee Lee

Tax law imposes a 20% penalty on substantial understatements of income tax, but taxpayers avoid that penalty by showing “substantial authority” supports the reporting position that causes the understatement. ...

Taxation

A Partnership Mark-to-Market Tax Election

David Hasen

The rules of Subchapter K of the Code impose substantial compliance burdens on partnerships and substantial administrative burdens on the government. ...

Taxation

The IRS’s Tax Determination Authority

Allen D. Madison

Even with severe negative consequences to cheating, a taxpayer has little incentive to comply with the tax laws if he believes the Service will not catch him. ...

Taxation

Fast-Pay Stock

David W. Mayo & Lucas R. Deppermann

The Service promulgated Regulation section 1.7701(l)-3 in an attempt to stop certain transactions commonly referred to as “fast-pay transactions.” ...

The Tax Lawyer

The Tax Lawyer, the nation’s premier, peer-reviewed tax law journal, is published quarterly as a service to its members by the American Bar Association Section of Taxation. Abstracts can be viewed by anyone, but full text pdfs are accessible only to members of the Section. Section members may also view the Spring 2018 issue of The Tax Lawyer in its entirety.

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Vol. 71, No. 1 - Fall 2017

The Tax Lawyer, Fall 2017

Articles

A Practitioner's Guide to Tax Evidence (2d ed. 2017): A Preview

Boundaries of the Prediction Model in Tax Law’s Substantial Authority

A Partnership Mark-to-Market Tax Election

The IRS’s Tax Determination Authority

Fast-Pay Stock

The Tax Lawyer

Now Available: The Tax Lawyer Audio Edition from ModioLegal

Subscribing

American Bar Association TM American Bar Association

Vol. 71, No. 1 - Fall 2017

The Tax Lawyer, Fall 2017

Articles

A Practitioner's Guide to Tax Evidence (2d ed. 2017): A Preview

Boundaries of the Prediction Model in Tax Law’s Substantial Authority

A Partnership Mark-to-Market Tax Election

The IRS’s Tax Determination Authority

Fast-Pay Stock

The Tax Lawyer

Now Available: The Tax Lawyer Audio Edition from ModioLegal

Subscribing