- Federal Income Taxation of Individuals
- Partnership Taxation
- Corporate Taxation
- Estate and Gift Taxation
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Examining the Tax Advantage of Founders' Stock Iowa Law Review (2012)
Recent commentary has described founders' stock as tax-advantaged because it converts founders' compensation income into capital gains. In this paper we describe various founders' stock strategies that offer this character conversion and then analyze whether ...
Taxing Structured Settlements Boston College Law Review (2010)
Congress has granted a tax subsidy to physically injured tort plaintiffs who enter into structured settlements. The subsidy allows these plaintiffs to exempt from the tax the investment yield imbedded within the structured settlement. The ...
On Discounted Partnership Interests and Adequate Consideration Virginia Tax Review (2009)
Early cases involving the government's invocation of section 2036(a) to combat the use of family limited partnerships to intentionally suppress the value of a decedent's gross estate focused on whether the decedent retained the beneficial ...
Questioning the Wisdom of Patent Protection for Tax Planning Virginia Tax Review (2007)
The topic of federal patent protection for tax planning strategies has received considerable recent attention, much of it from a tax bar whose overall incredulity concerning the patentability of tax advice has been transformed into ...
The Supreme Court's Casual Use of the Assignment of Income Doctrine University of Illinois Law Review (2006)
In early 2005, the U.S. Supreme Court answered a question that had been plaguing courts for years: whether plaintiffs should be taxed on the portion of contingent fee awards paid to their attorneys. The Court ...
Kimbell v. United States: The Rise and Apparent Fall of the Section 2036 Argument Against FLPs Tax Notes (2004)
In this report, Professor Hellwig examines the application of section 2036 to family limited partnerships in the context of the Fifth Circuit's recent opinion in Kimbell v. United States. After describing how the government developed ...
Judicial Activism is Not the Solution to the Attorney's Fee Problem Tax Notes (2002)
The report responds to criticism of the Tax Court's decision in Biehl v. Commissioner, in which the court determined that contingency fees paid to the taxpayer's attorney in employment litigation did not constitute an above-the-line ...
Estate of Strangi, Section 2036, and the Continuing Relevance of Byrum Tax Notes (2002)
This report analyzes the potential application of section 2036(a) to limited partnerships employed for estate planning purposes, using the facts of Tax Court case of Estate of Strangi v. Commissioner as a guide. Particular emphasis ...