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
Quantitative Inequity in Line-Drawing Analysis, ExpressO (2011)
Line-drawing analysis finds application in every area of law. Criminal law draws a line between...
The Allure and Illusion of Partners' Interests in a Partnership, University of Cincinnati Law Review (2011)
Favorable tax treatment and management flexibility make tax partnerships very popular. For starters, tax partnerships,...
The Law School Firm (with Robert J. Rhee), South Carolina Law Review (2011)
This Article introduces the concept of the law school firm. The concept calls for law...
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...
Books
Taxation and Business Planning for Real Estate Transactions (2011)
This book focuses on tax planning in the real estate context. To adequately provide tax-planning...
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
Three Cheers for Passthrough Taxation, Tax Notes (2011)
This report addresses recent suggestions by the Obama administration, lawmakers, and others that some passthrough...
The Effect of Like-Kind Property on the Section 704(c) Anti-Mixing Bowl Rules (with Douglas L. Longhofer), Tax Management Real Estate Journal (2011)
Section 704(c)(2) provides an exception to the section 704(c)(1)(B) anti-mixing bowl rules. Commentators have observed...
Do Serial Exchangers Get Cash, with Extra Boot, Under New Letter Ruling? (with Kelly E. Alton and Alan S. Lederman), Journal of Taxation (2011)
Related-party exchanges raise the issue of improper extension of the Section 1031(a)(3) 45-day identification and...
Series LLCs in Real Estate Transactions (with Mathews Vattamala), Real Property, Trust & Estate Law Journal (2011)
Series limited liability companies are a fairly new form of business entity. Some observers worry...
The Liability-Offset Theory of Peracchi (with Douglas L. Longhofer), The Tax Lawyer (2011)
Peracchi v. Commissioner is a lightning rod for commentators and the bane of students of...