My scholarship focuses on taxation of property transactions and noncorporate entity taxation. 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
The 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...
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....
Policy and Theoretical Dimensions of Qualified Tax Partnerships, Kansas Law Review (2008)
Qualified tax partnerships are arrangements that come within the definition of tax partnership but elect...
A Win-Win Proposal for Analyzing Profits-Only Partnership Interests (Including Carried Interests), ExpressO (2008)
The proper tax treatment of profits-only partnership interests is an unsolved aspect of tax law....
Partnership Tax Allocations and the Internalization of Tax-Item Transactions, South Carolina Law Review (2008)
Studies in the theory of the firm help explain partnership attributes and the relationships partners...
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 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...
Safe Harbors and Careful Planning Make Deferred Exchanges a Valuable Tool, Journal of Taxation of Investments (2008)
This Article describes the section 1031 deferred exchange safe harbors. It describes how property owners...
Related-Party Like-Kind Exchanges (with Kelly Alton and Alan Lederman), Tax Notes (2007)
Related-party exchanges under section 1031 raise many technical, theoretical, and policy issues. Unfortunately, this topic...
Tax Opinions in TIC Offerings and Reverse TIC Exchanges (with Todd D. Keator), Tax Management Real Estate Journal (2007)
Property owners often acquire tenancy-in-common (TIC) interests as replacement property in section 1031 exchanges. Generally,...
Section 1031 Alchemy: Transforming Personal Tangible and Intangible Property Into Real Property (with Kelly E. Alton), Real Estate Taxation (2007)
Section 1031 nonrecognition applies only to exchanges of like-kind properties. Although real property generally is...