Bristol-Meyers' Disappearing Gain
Recently, an inadvertent Internal Revenue Service disclosure revealed atax controversy involving Bristol-Myers Squibb’s contribution of zero-basis,high-value intangibles to a related foreign partners…
The Tax Lawyer | Fall 2022
Volume 76, Issue 1
Articles
Supervisory Approval of Penalties: The Opening of a Graev Pandora's Box
Section 6751(b) of the Internal Revenue Code requires supervisoryapproval in writing prior to assessment of certain penalties. Enacted in 1998as part of the Internal Revenue Service (the “Service”) R…
A Study of Tax Lawyers Discussing Duties
This Article reports the first qualitative empirical study of U.S. tax lawyers.We interviewed women lawyers who were tax planning specialists.
Practical Considerations in Starting and Operating an Academic Low-Income Tax Clinic
Low-income taxpayer clinics (“LITCs”) provide legal assistance tounderserved clients with active federal tax controversies, conducteducational outreach to low-income and English-as-a-second-languaget…
State & Local Tax
A Requiem for the Physical Presence Rule: Deconstructing and Refuting South Dakota v. Wayfair, Inc.
South Dakota v. Wayfair exemplifies a truism of Supreme Court decisions:they can be overruled, but they cannot be freely undone.