|Present||Mark and Evelyn Trammell Professor of Law and Tax Clinic Director, Georgia State University College of Law ‐ Philip C. Cook Low-Income Taxpayer Clinic|
|B.S., Syracuse University|
|J.D., St. John's University School of Law|
|LL.M., New York University Graduate School of Law|
Proposed Regulations Perpetuate Income Distortion Tax Notes (2011)
This article discusses the proposal to modify regulations that determine a debt instrument’s issue price whenever there is an exchange of an instrument involving publicly traded property. Under both proposed and current regulation section 1.1273-2, ...
New Capitalization Rules: Their Sweeping Effect on Financial Institutions Journal of the Taxation & Regulatory Finance Institute (2004)
Final regulations issued under IRC Section 263(a) prescribe a sweeping set of new rules that will affect the tax treatment of a variety of amounts paid by taxpayers to acquire or to create intangibles, including ...
Renegotiated Debt: The Search for Standards Tax Lawyer (1991)
This article examines, from the creditor’s standpoint, four basic tax issues that must be resolved to properly report the tax effect of debt renegotiation: first, the circumstances under which a debt renegotiation is properly classified ...
Ineffective and Inequitable: The Section 265(a) Interest Disallowance Wake Forest Law Review (1990)
This article argues for the repeal of Code section 265(a) because it is ineffective, creates horizontal inequities, and represents overwhelming administrative enforcement difficulties. Consistent with the repeal of the section should be a repeal of ...
The Franchise Tax Exception to the Federal Exemption Statute Banking Law Journal (1985)
This article examines the origin and history of franchise taxes, the authority of state and local governments to impose such taxes, and the legislative and judicial responses to the problem. It concludes that the franchise ...
Bank Shares Taxes: Another Trap for the Unwary Draftsman Tennessee Law Review (1984)
This article explores the foundation and development of judicial doctrines that call for the elevation of substance over form and analyzes their application to state franchise taxes in the context of the immunity from state ...