Publications

“New Court Decisions Herald Expanded Protection for Accountant-Client Communications” (AICPA Journal of Accountancy, January 2014).
“The Limits of Mayo Foundation v. United States: Retroactive Regulations” (Tax Notes, April 18, 2011).
“Developments in Economic Substance: How Codification and New Case Law Will Change the Rules” (BNA Tax Management Real Estate Journal, April 7, 2010).
“Managing Tax Accrual Workpapers after Textron” (Tax Notes, May 4, 2009).

“Officials Optimistic Government Will Prevail in Preparer Oversight Appeal” (Tax Analysts, March 4, 2013)
“News Analysis: A Failed Attempt to Vary the Variance Doctrine” (Tax Analysts, October 22, 2012)
“Practitioners Still Seeking Tax Shelter Success as Courts Side with Government” (Tax Analysts, January 20, 2012)
“News Analysis: Federal Circuit Plays It Safe in En Banc Reconsideration of Bush” (Tax Analysts, August 30, 2011)
“Fifth Circuit Finds No Omission, Deepens Circuit Split” (Tax Analysts, February 10, 2011)
“News Analysis: Did the Federal Circuit Just Issue Another Murphy?” (Tax Analysts, April 12, 2010)
“Practitioners, Government Officials Debate Codification of Economic Substance” (Tax Analysts, November 20, 2009)
Special Treatment for Tax Regulations Faces Latest Legal Test (Bloomberg Tax, April 23rd 2020)

Latest Development

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