My scholarship focuses on taxation of property transactions and business arrangements. In particular, I am interested in the theoretical aspects of partnership taxation and the proper tax treatment of members of disregarded arrangements. My publications range from theoretical scholarly articles published in law reviews, to technical doctrinal expositions published in the country's premier professional tax journals, to works intended for the general public.
Scholarly Articles
Residual-Risk Model for Classifying Business Arrangements, Florida State University Law Review (2010)
Tax law classifies business arrangements as one of three general structures: (1) disregarded arrangements, (2)...
Aggregate-Plus Theory of Partnership Taxation, Georgia Law Review (2009)
This Article presents a theory of partnership taxation. To provide context for the presentation, the...
Open Tenancies-in-Common, Seton Hall Law Review (2009)
Tax law (section 1031 in particular) has spawned a new investment vehicle—open tenancies in common....
Profits-Only Partnership Interests, Brooklyn Law Review (2009)
Profits-only partnership interests grant service-providing partners an interest in the profits of a partnership but...
The Like-Kind Exchange Equity Conundrum, Florida Law Review (2008)
The tax-free treatment of like-kind exchanges presents one of tax law’s most compelling equity conundrums....
Books
Tax-Free Like-Kind Exchanges (2008)
This is a comprehensive treatise on section 1031 like-kind exchanges.
Tax-Free Swaps: Using Section 1031 Like-Kind Exchanges to Preserve Investment Net Worth (2007)
Property owners of all sizes realize that exchanging property under section 1031 presents tax-saving possibilities....
Doctrinal Articles
Like-Kind Exchanges and Qualified Intermediaries (with Paul L.B. McKenney and David Shechtman), Tax Notes (2009)
The economic downturn has depressed the real estate market, a significant component of the section...
Workout-Driven Exchanges (with Todd D. Keator), Real Estate Taxation (2009)
Market forces in a depressed real estate market often lead to foreclosures, which may generate...
A Win-Win Proposal for Analyzing Profits-Only Partnership Interests, Tax Notes (2008)
The proper tax treatment of profits-only partnership interests is an unsolved aspect of tax law....
Financing Reverse Exchanges and Safeguarding Exchange Proceeds, Journal of Taxation and Regulation of Financial Institutions (2008)
Over the last several years, reverse exchanges have become a fixture of section 1031. A...
Like-Kind Exchanges of Personal-Use Residences (with Alex Hamrick), Tax Notes (2008)
The law governing section 1031 exchanges of personal-use residences ranges from very explicit, in the...