Books
The Death of the Income Tax (2013). [Abstract]
Editor, Federal Revenue Rulings on Corporate Acquisitions, Mergers, Divisions and Formations (1982).
Articles
Reimagining a U.S. Corporate Tax Increase as a Supplemental Subtraction VAT, Florida Tax Review (forthcoming 2023).
Partnership Revaluations: Book-ups Are Your Friends (Usually) - Planning with Revaluations and Their Interplay with Section 704(c), 74 Tax Lawyer 345 (2021). [Full Text]
The Target Method for Partnership Special Allocations and Why It Should Be Safe-Harbored, 69 Tax Lawyer 663 (2016), reprinted in PLI, 2017 Tax Partnership Practice Series: Course Materials for Tax Planning for Domestic & Foreign Partnerships, LLCs, Joint Ventures & Other Strategic Alliances (2017, 2018, 2019). [Abstract]
E-VATAn Electronically Collected Progressive
Consumption Tax, 128 Tax Notes 1351 (2010). [Full Text]
The Aches and Pains of Transition to a Consumption Tax: Can We Get There from Here?, 26 Virginia Tax Review 447 (2007). [Full Text]
E Tax: The Flat Tax as an Electronic Credit VAT, 108 Tax Notes 1168 (2005). [Full Text]
To Praise the AMT or to Bury It, 24 Virginia Tax Review 835 (2005). [Full Text]
The U.S. Consumption Tax: Evolution, Not Revolution, 57 Tax Lawyer 1 (2003), excerpts reprinted in Tax Policy: Readings and Materials (Philip Oliver, ed. 2d ed. 2003). [Full Text]
Choice of Entity for a Venture Capital Start-up: The Myth of Incorporation, 55 Tax Lawyer 923 (2002). [Full Text]
E-Tax: Fundamental Tax Reform and The Transition to a Currency - Free Economy, 20 Virginia Tax Review 1 (2000). [Full Text]
Government Precommitment to Tax Incentive Subsidies: The Impact of U.S. v. Winstar Corp. et. al. on Retroactive Tax Legislation, 14 American Journal of Tax Policy 1 (1997). [Full Text]
Nonrecourse Debt in Excess of Fair Market Value: The Confluence of Basis, Realization, Subchapter K and the Need for Consistency, 51 Tax Lawyer 41 (1997). [Full Text]
The Tax Treatment of Limited Liability Companies: Law in Search of Policy, 50 Business Lawyer 995 (1995). [Full Text]
Tax Subsidies: One Time vs. Periodic An Economic Analysis of the Tax Policy Alternatives, 49 Tax Law Review 305 (1994). [Full Text]
The Kingdom of Pal: A Parable of Tax Shelters and the Passive Activity Loss Rules, 51 Tax Notes 225 (1991) [Full Text]
Recent Approaches to the Trade or Business Requirement of Section 174: Unauthorized Snow Removal, 8 Virginia Tax Review 861-902 (1989). [Full Text]
The Passive Activity Loss Rules: Planning Considerations, Techniques, and a Foray Into Never-Never Land, 15 Journal of Real Estate Taxation 3 (1987). [Full Text]
Tax Planning for Interest after TRA 1984: Unstated Interest and Original Issue Discount,in 43rd Annual N.Y.U. Institute on Federal Taxation 1 (1985). [Full Text]
Interest Elements in Tax Planning, in N.Y.U. Tax Institute: 1983 Conference on Tax Planning for the Individual 129. [Full Text]
Fair Market Value in the Tax Law: Replacement Value or Liquidation Value, 60 Texas Law Review 833 (1982). [Full Text]
Open Transaction Treatment for Deferred Payment Sales After the Installment Sales Act of 1980, 34 Tax Lawyer 605 (1981). [Full Text]
Lifetime Gifts: A Quantitative Approach, 1980 The Tax Advisor 83. [Full Text]