Taxation & Estate Planning

George Washington Tells a Lie to 200 Applicants: 'You're Admitted'

Posted on February 18, 2010
Washington Post, GWU e-Mail Welcomes Rejected Early-Decision Applicants: About 200 students who had sought early-decision admission to George Washington University received an e-mail last week that proclaimed "Congratulations" and welcomed them to the Class of 2014 -- for several hours...

Seto: The Problem with Bonus Depreciation

Posted on February 18, 2010
Theodore P. Seto (Loyola-L.A.) has posted The Problem with Bonus Depreciation, 126 Tax Notes 782 (Feb. 8, 2010), on SSRN. Here is the abstract: Bonus depreciation encourages businesses to reallocate funds from labor to capital and thereby depresses the demand for labor...

ABA Tax Section Webcast Today on Report of National Taxpayer Advocate Nina Olson

Posted on February 18, 2010
The ABA Tax Section offers a teleconference and webcast today on Report of the National Taxpayer Advocate Nina Olson from 1:00 - 2:30 p.m. EST: The ABA Section of Taxation is pleased to present a special 90-minute teleconference featuring Nina Olson, IRS National Taxpayer Advocate, who will discuss the major...

Blank: Public Shaming of Corporate Tax Abuse

Posted on February 18, 2010
Joshua D. Blank (NYU) has published What's Wrong With Shaming Corporate Tax Abuse, 62 Tax L. Rev. 539 (2009). Here is the abstract: The public spotlight has emerged as a potential instrument for stopping corporations from pursuing shady tax shelters. The inadequacy of the exclusive use of monetary penalties and...

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Gregg Polsky Leaves Florida State for North Carolina

Posted on February 18, 2010
Faculty Lounge and Feminist Law Professors report that Gregg D. Polsky, Sheila M. McDevitt Professor of Law at Florida State, has accepted a senior offer at North Carolina. Gregg previously was a tenured professor at Minnesota, a visiting professor at Florida, and Professor in Residence at the IRS's Office of...

Pilot Deliberately Crashes Into IRS Office Building in Austin, Blames Tax Reform Act of 1986

Posted on February 18, 2010
Andrew Joseph Stack, 53, intentionally flew a small plane into an Austin, Texas building housing IRS offices and posted a seven-page anti-IRS manifesto entitled, Well Mr. Big Brother IRS Man... Take My Pound of Flesh and Sleep Well. Associated Press Bloomberg Christian Science Monitor CNN L...

Burke Presents Anatomy of a Tax Shelter Today at Indiana

Posted on February 18, 2010
Karen C. Burke (San Diego) presents COBRA Strikes Back: Anatomy of a Tax Shelter, 62 Tax Law. 59 (2008) (with Grayson McCouch (San Diego)) at Indiana-Bloomington today via video conference as part of its Tax Policy Colloquium Series organized by Ajay K...

Brown Presents Automatic Lifetime Income and Retirement Income Security Today at NYU

Posted on February 18, 2010
Jeffrey Brown (University of Illinois, College of Business) presents Automatic Lifetime Income as a Path to Retirement Income Security at NYU today as part of its Colloquium Series on Tax Policy and Public Finance. The co-convenors of the colloquium are Daniel Shaviro (NYU) & Mihir Desai (Harvard Business School)...

Mikos: State Taxation of Marijuana

Posted on February 18, 2010
Robert Mikos (Vanderbilt) has posted Why Crime Doesn't Pay: Thoughts on State Taxation of Marijuana Distribution and Other Federal Crimes on SSRN. Here is the abstract: The financial crisis has breathed new life into proposals to reform marijuana law...

Caron: Ten Estate Planning Advantages of Limited Liability Companies

Posted on February 17, 2010
I have posted Ten Estate Planning Advantages of Limited Liability Companies, 70 Tax Notes 998 (1996), on SSRN. Here is the abstract: In the eight years since the Service blessed the Wyoming limited liability company (LLC) statute, there has been an explosion of interest in LLCs, which are now available...

Law Review Circulation Continues to Plummet

Posted on February 17, 2010
Ross E. Davies (George Mason) has posted Law Review Circulation 2009: The Combover, Green Bag Almanac & Reader 419 (2010). Here is the abstract: For our second annual study of the law review business [see the first study here], we added circulation data for four flagship law reviews (UCLA, Texas,...

Obama's Proposed International Tax Increase Is Business's #1 Tax Concern

Posted on February 17, 2010
Miller & Chevalier (Washington, D.C.) today released its 2010 Tax Policy Forecast Survey measuring the current perspectives and attitudes of leading corporate tax executives on the direction of tax policy in the coming year. From the Executive Summary: Respondents to the fourth annual survey say that even more than last...

Abolish NALP Now

Posted on February 17, 2010
National Law Journal op-ed, Abolish NALP Now; Current Process Fails to Serve Interests of Students, Law Schools or Employers, by Peter Kalis (Chairman & Global Managing Partner, K&L Gates): Law is a mature profession and an immature industry. Nowhere is the immaturity more evident than in the way in which...

CBPP Tax Reports

Posted on February 17, 2010
Oregon Voters' Approval of Tax Increase Noteworthy as Federal Tax Debate Opens: "Oregonians? decisive vote last month to raise taxes on households making over $250,000 calls into question the conventional wisdom that tax-increase proposals are politically untenable regardless of their merit on economic, budgetary, and equity grounds...

Marsan: The Green Book's International Tax Provisions

Posted on February 17, 2010
Dean Kirk Marsan (former Senior Tax Counsel, Lehman Brothers) has posted An Analysis of the Green Book's International Tax Enforcement Provisions for U.S. Persons, 87 Taxes 33 (July 2009), on SSRN.

Obama Administration to Increase IRS Audits This Year

Posted on February 17, 2010
CNN Money, Tax Audits: Uncle Sam Wants You!: Worried about a tax audit? Maybe you should be. More Americans than ever may be subject to unwanted attention from the IRS this season as the government pumps billions of dollars into tax collection. More than 1...

Borden: Taxing Shared Economies of Scale

Posted on February 17, 2010
Bradley T. Borden (Washburn) has published Taxing Shared Economies of Scale, 61 Baylor L. Rev. 721(2009). Here is the abstract: Economies of scale exist if long-run average costs decline as output rises. All else being equal, the decline in average costs should lead to greater profitability, making economies of scale...

Forbes 2010 Tax Guide

Posted on February 17, 2010
Forbes has published a 2010 Tax Guide: Tips on how to save money on your 2009 return, cut your tax bill in 2010 and beyond and avoid trouble with the IRS. Earn Tax-Free Income, by William Baldwin: "Tax rates are going up, so it pays to find sources of income...

Sens. Wyden, Gregg to Introduce Bipartisan Tax Reform Bill

Posted on February 17, 2010
Senators Ron Wyden (D-Ore.) and Judd Gregg (R-N.H.) announced today that they plan to introduce comprehensive tax reform legislation when the Senate returns next week: For more than two years, we have been working together on tax reform legislation. While the prevailing wisdom is that there is no such thing...

Ms. JD

Posted on February 16, 2010
Ms. JD: Ms. JD is pleased to announce the Ms. JD Fellowship program, which will select 20 of the most promising second-year law students in the country and provide them with one-on-one career mentorship from an accomplished female attorney. Who Are The Mentors? Fellowship mentors will be assigned to the...

Notre Dame Seeks to Hire Director for Tax & Estate Planning Institute

Posted on February 16, 2010
The Notre Dame Tax & Estate Planning Institute is seeking to hire a Program Director to take over for Regis Campfield (SMU): The University of Notre Dame invites applications for a Program Director to organize and implement all aspects of the annual Notre Dame Tax & Estate Planning Institute...

Gerzog: Check-the-Box Regs and Gift Tax Discounts

Posted on February 16, 2010
Wendy C. Gerzog (Baltimore) has posted Check-the-Box Regs and Gift Tax Discounts, 126 Tax Notes 871 (Feb. 15, 2010), on SSRN. Here is the abstract: This article discusses the recent Tax Court decision in Pierre [v. Commissioner, 133 T.C. No. 2 (2009)] and the effect for gift tax purposes of...

Caplin, Cunningham & Engler: Rectifying the Tax Treatment of Shared Appreciation Mortgages

Posted on February 16, 2010
Andrew Caplin (NYU, Stern School of Business), Noël B. Cunningham (NYU) & Mitchell L. Engler (Cardozo) have published Rectifying the Tax Treatment of Shared Appreciation Mortgages, 62 Tax L. Rev. 505 (2009). Here is the abstract: The current mortgage crisis has increased interest in innovative shared appreciation mortgages (SAMs)...

Shaviro: The Case Against Foreign Tax Credits

Posted on February 16, 2010
Daniel N. Shaviro (NYU) has posted The Case Against Foreign Tax Credits on SSRN. Here is the abstract: In international tax policy debate, it is usually assumed that, if one chooses not to exempt residents? foreign source income, the preferred system would offer foreign tax credits...

Tax Stimulus, Law School Edition

Posted on February 16, 2010
Robert G. Nassau (Syracuse): This is not a terribly novel idea, but wouldn?t NOW be a great time for the IRS to hire 2,500 of our law school graduates and put them to work auditing people and corporations? This would create 2,500 well-paying jobs that more than paid for themselves.

Altshuler, Lim & Williams: Desperately Seeking Revenue

Posted on February 16, 2010
Rosanne Altshuler (Director, Tax Policy Center), Katherine Lim (Research Assistant, Tax Policy Center) & Roberton Williams (Senior Fellow, Tax Policy Center) presented Desperately Seeking Revenue at the January 15, 2010 conference on Train Wreck: A Conference on America's Looming Fiscal Crisis at USC...

Kaplow: Utility from Accumulation

Posted on February 16, 2010
Louis Kaplow (Harvard) has posted Utility from Accumulation on SSRN. Here is the abstract: The possibility that individuals may derive utility from the mere fact of holding wealth has long been recognized. A simple intertemporal model featuring utility from accumulation is used here to examine consumption and savings, the choice...

The Geithner Effect on Taxpayer Attitudes

Posted on February 16, 2010
The IRS Oversight Board today released the results of its 2009 Taxpayer Attitude Survey of 1,000 respondents. This is the eighth year the board has conducted the survey. Perhaps not surprisingly in light of the well publicized tax transgressions of Treasury Secretary Timothy Geithner and other Obama Administration officials and...

Checkoff California

Posted on February 16, 2010
Checkoff California: California is one of 41 states that allows taxpayers to make a voluntary contribution to a range of causes when completing and filing their yearly state tax return. Since 1984, California's tax check-off program has raised over $89 million and provided critical funding to public health, social service,...

NY Times Tax Section

Posted on February 15, 2010
The Sunday New York Times had a special section on taxes: With Rules in Flux, It?s a Tough Time for Tax Strategies, by Robert D. Hershey Jr. "What?s the future of the estate tax? The Bush tax cuts? The alternative minimum tax? For taxpayers, it?s a game of wait and...

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