Volume 43, Issue 1
I write in this Tax Times urging you to consider “phoning a friend” (or the 2020s equivalent—texting, social media, blogging, chatting over a coffee, etc.) to share how the Section enhances your prof…
Jonathan R. Black is an Associate with Caplin & Drysdale in the Tax Disputes & Tax Litigation and Complex Litigation practice groups. Prior to private practice, Mr.
This article addresses the impact of allocating consideration received among asset(s) sold, use of a one-day note for federal and state planning, potential benefits of opting out of installment sale…
This piece explores the merits of avoiding tax on a Roth conversion by combining the conversion with either an equal qualified charitable distribution that satisfies part of an annual required minimu…
This article summarizes the tips for effective Tax Court advocacy presented in the ABA’s virtual CLE presentation titled "Making Your Case in Tax Court: Advocacy Tips."…
This article explains substance-over-form doctrines in light of the GSS Holdings (Liberty) Inc. v. United States, in which the United States Court of Federal Claims conflated the step transaction and…
Discussing Moore v. U.S., this article examines state laws, academic articles, newspapers, and congressional statements during passage of the 16th Amendment to demonstrate the clear lack of a public…
This essay argues that the tax code should offer greater incentives for gym use and presents a few ways to achieve this objective including a fitness tax credit and/or a modification of fringe benefi…
The Tax Section remembers longtime member J. Leigh Griffith, a leader of the LLCs & LLPs Subcommittee of the Partnerships & LLC Committee.
The Tax Section has published the latest editions of its two annual SALT deskbooks. The Sales and Use Tax Deskbook is now in its 36th edition, and the Property Tax Deskbook is in its 28th edition.
To the tune of Sweet Caroline written and recorded by Neil Diamond (1969). When I awake / Although it may be Monday / I feel like it’s still Sunday / Here in my chair.