Rethinking "Insurance," Especially after A.I.G., Denver University Law Review (2009)


Tenure Buyouts: Employment Death Taxes and the Curious Obesity of "Wages", University of Pittsburgh Law Review (2009)

Prior to January of 1994, institutions of higher education could appeal to an exemption in...



Shock, Awe, and Expropriation: The Act of State Doctrine and Loss Deductions under Section 165 of the Internal Revenue Code, Tulane Law Revue (2008)

The Act of State doctrine generally dictates that American courts not sit in judgment with...



Tax Terrorism: Nasty Truths About Investor Control Theory and the Accommodation of Social Security Privatization, Mercer Law Review (2006)

The privatization of Social Security could have promised profound challenges to the investor control doctrine...



Transfiguration of the Deadbeat Dad and the Greedy Octogenarian: An Intratextualist Critique of Tax Refund Seizures, Kansas Law Review (2006)

In light of the federal government's plenary collection powers, the states have, for several years,...


Contributions to Books

Life Insurance Companies, The Law of Federal Income Taxation (2000)

Unpublished Papers


Serfs at the Mercy of a Hungry Beast: Aggressive Regressivity, Private Equity, and the Quandary of the St. Luke Imperative (2008)

Currently, there exists a split in the U.S. Courts of Appeals with respect to whether...