Daniel Goldberg

Professor of Law




(410) 706-3871


(410) 706-2184

Photo of Daniel Goldberg


  • AB, 1968, University of Rochester
  • JD, 1971, Harvard University


Professor Goldberg’s specialty is tax law. During his years on the faculty, he has taught courses in income taxation, various aspects of business taxation (partnership and corporate), tax policy, international taxation, and law and economics. He has received the Outstanding Teaching Award by vote of the graduating class. Over the years, he has lectured at various programs for tax lawyers, including the New York University Institute on Federal Taxation.

Professor Goldberg’s research interests include tax policy issues, and he is the author of the book The Death of the Income Tax: A Progressive Consumption Tax and the Path to Fiscal Reform, published by Oxford University Press. The book explains why the current income tax is fatally flawed and proposes a plan to replace it with a progressive consumption tax. He also has published several articles on aspects of the income tax/consumption tax choice as well as other tax policy issues in scholarly journals including the Tax Law Review, the Tax Lawyer, the Virginia Tax Review, and Tax Notes. Professor Goldberg’s research interests also extend to issues under the current income tax primarily related to business and real estate transactions, partnership taxation, and venture capital. He has published several articles in law reviews in these areas as well.

While on the faculty, Professor Goldberg has done consulting with law firms in Washington, D.C. and Baltimore, and has served as professor in residence in the National Office of the Internal Revenue Service. Prior to joining the faculty in 1978, he practiced full time for law firms in New York and Washington, D.C. Most notably, he brings these experiences into the classroom and into his scholarly writing.

Professor Goldberg was a cum laude graduate of Harvard Law School and a member of the Harvard Law Review. He graduated with High Honors from the University of Rochester, where he was elected to Phi Beta Kappa and was awarded the John Dows Mairs Prize for Excellence in Economics.


The Death of the Income Tax (2013). Abstract

Editor, Federal Revenue Rulings on Corporate Acquisitions, Mergers, Divisions and Formations (1982).


Reimagining a U.S. Corporate Tax Increase as a Supplemental Subtraction VAT, 26 Florida Tax Review 369 (2023). Abstract

Partnership Revaluations: Book-ups Are Your Friends (Usually) - Planning with Revaluations and Their Interplay with Section 704(c), 74 Tax Lawyer 345 (2021). Abstract

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-VAT—An Electronically Collected Progressive Consumption Tax, 128 Tax Notes 1351 (2010). Abstract

The Aches and Pains of Transition to a Consumption Tax: Can We Get There from Here?, 26 Virginia Tax Review 447 (2007). Abstract

E Tax: The Flat Tax as an Electronic Credit VAT, 108 Tax Notes 1168 (2005). Abstract

To Praise the AMT or to Bury It, 24 Virginia Tax Review 835 (2005). Abstract

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). Abstract

Choice of Entity for a Venture Capital Start-up: The Myth of Incorporation, 55 Tax Lawyer 923 (2002). Abstract

E-Tax: Fundamental Tax Reform and The Transition to a Currency - Free Economy, 20 Virginia Tax Review 1 (2000). Abstract

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). Abstract

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). Abstract

The Tax Treatment of Limited Liability Companies: Law in Search of Policy, 50 Business Lawyer 995 (1995). Abstract

Tax Subsidies: One Time vs. Periodic – An Economic Analysis of the Tax Policy Alternatives, 49 Tax Law Review 305 (1994). Abstract

The Kingdom of Pal: A Parable of Tax Shelters and the Passive Activity Loss Rules, 51 Tax Notes 225 (1991) Abstract

Recent Approaches to the Trade or Business Requirement of Section 174: Unauthorized Snow Removal, 8 Virginia Tax Review 861-902 (1989). Abstract

The Passive Activity Loss Rules: Planning Considerations, Techniques, and a Foray Into Never-Never Land, 15 Journal of Real Estate Taxation 3 (1987). Abstract

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). Abstract

Interest Elements in Tax Planning, in N.Y.U. Tax Institute: 1983 Conference on Tax Planning for the Individual 129. Abstract

Fair Market Value in the Tax Law: Replacement Value or Liquidation Value, 60 Texas Law Review 833 (1982). Abstract

Open Transaction Treatment for Deferred Payment Sales After the Installment Sales Act of 1980, 34 Tax Lawyer 605 (1981). Abstract

Lifetime Gifts: A Quantitative Approach, 1980 The Tax Advisor 83. Abstract