Vol. 76, No. 1 - Fall 2022

Articles

Taxation

Bristol-Meyers' Disappearing Gain

by Karen C. Burke

Recently, an inadvertent Internal Revenue Service disclosure revealed a tax controversy involving Bristol-Myers Squibb’s contribution of zero-basis, high-value intangibles to a related foreign partnership that would potentially save $1.4 billion...

Taxation

Supervisory Approval of Penalties: The Opening of a Graev Pandora's Box

by Monica Gianni

Section 6751(b) of the Internal Revenue Code requires supervisory approval in writing prior to assessment of certain penalties. Enacted in 1998 as part of the Internal Revenue Service (the “Service”) Restructuring and Reform Act...

Taxation

A Study of Tax Lawyers Discussing Duties

by Michael Hatfield and Michelle Kwon

This Article reports the first qualitative empirical study of U.S. tax lawyers. We interviewed women lawyers who were tax planning specialists.

Taxation

Practical Considerations in Starting and Operating an Academic Low-Income Tax Clinic

by Amy Spivey and Manoj Viswanathan

Low-income taxpayer clinics (“LITCs”) provide legal assistance to underserved clients with active federal tax controversies, conduct educational outreach to low-income and English-as-a-second-language taxpayers...

State and Local Tax

Taxation

A Requiem for the Physical Presence Rule: Deconstructing and Refuting South Dakota v. Wayfair, Inc.

by Eric Smith

South Dakota v. Wayfair exemplifies a truism of Supreme Court decisions: they can be overruled, but they cannot be freely undone.

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.

Subscribing

If you are an ABA member, you can receive The Tax Lawyer when you join the Section of Taxation. Anyone can subscribe to The Tax Lawyer by contacting the ABA Service Center at [email protected].

Renew Your ABA Membership

Vol. 76, No. 1 - Fall 2022

The Tax Lawyer, Fall 2022

Articles

Bristol-Meyers' Disappearing Gain

Supervisory Approval of Penalties: The Opening of a Graev Pandora's Box

A Study of Tax Lawyers Discussing Duties

Practical Considerations in Starting and Operating an Academic Low-Income Tax Clinic

State and Local Tax

A Requiem for the Physical Presence Rule: Deconstructing and Refuting South Dakota v. Wayfair, Inc.

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect

Renew Your ABA Membership

American Bar Association TM American Bar Association

Vol. 76, No. 1 - Fall 2022

The Tax Lawyer, Fall 2022

Articles

Bristol-Meyers' Disappearing Gain

Supervisory Approval of Penalties: The Opening of a Graev Pandora's Box

A Study of Tax Lawyers Discussing Duties

Practical Considerations in Starting and Operating an Academic Low-Income Tax Clinic

State and Local Tax

A Requiem for the Physical Presence Rule: Deconstructing and Refuting South Dakota v. Wayfair, Inc.

The Tax Lawyer

Subscribing

ABA Resources

The ABA

Connect