Published inJackeltaxlawHiring More Agents: A Good Start but Not the Sole SolutionExcerpted from Tax Notes.Sep 24, 2023Sep 24, 2023
Guaranteed Payment/707(c) References to be Coordinated if Section 707(c) is RepealedI. SummarySep 5, 2023Sep 5, 2023
Published inJackeltaxlawThe ALI Centennial and the Future of Tax ProjectsAdapted from a book review published in Tax Notes Federal on August 28, 2023. A freely available link not behind Tax Analysts paywall is…Aug 27, 2023Aug 27, 2023
Published inJackeltaxlawWe Need Partnership Tax ReformAdapted from a letter to the editor of Tax Notes on Aug. 7, 2023Aug 3, 2023Aug 3, 2023
Published inJackeltaxlawPotential Implications of Supreme Court Review in Moore CaseBased in part in a letter to the editor of Tax Notes on July 10, 2023.Jul 11, 2023Jul 11, 2023
Published inJackeltaxlawSome Brief Comments on the Section 6418 Transfer Credit Proposed RegulationsJune 16, 2023Jun 16, 2023Jun 16, 2023
Published inJackeltaxlawAggregate-Entity Redux(This article is reprinted from a letter to the editor of Tax Notes Federal published on May 8, 2023)May 7, 2023May 7, 2023
Published inJackeltaxlawTax Court Clarifies What A Profits Interest IsThe U.S. Tax Court has held in ES NPA Holding, T.C. Memo 2023–55, that an interest in a partnership granted for services was a profits…May 4, 2023May 4, 2023
Published inJackeltaxlawTAX NOTES FEDERAL AND TAX NOTES TODAY FEDERAL : COLLECTION OF LETTERS TO THE EDITORThis is a collection of links to letters to the editor of Tax Notes Federal that I have written over the past decade and a half. They…Mar 20, 2023Mar 20, 2023
Published inJackeltaxlawStatutory Conflicts, Interpretation Animate Recent IRS Guidance(For a parallel analysis of these issues in my latest letter to the editor of Tax Notes Federal, see my letter to the editor, here).Mar 18, 2023Mar 18, 2023
