Paul L. Caron
Dean
Pepperdine Caruso
School of Law
ABA Tax Section
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As part of National Pro Bono Celebration Week, the ABA Tax Section is offering three webcasts this week: Tax Court Controversy: The Nuts and Bolts of Pro Bono Representation (Oct. 25)Providing pro bono assistance to low income taxpayers is a valuable service to the community and a rewarding experience. Many tax practitioners are surprised at…
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ABA Tax Section Midyear Meeting
The ABA Tax Section Fall meeting concludes today in Denver. The full program is here. Tax Profs with speaking roles today include: Employee Benefits and Employee Benefits Group: Ethics Issues in Employee Benefits — Andrew M. Perlman (Suffolk) Low Income Taxpayers: Benefits and Pitfalls of Advanced Pre-Refund Compliance Checks — Keith Fogg (Villanova), Scott Schumacher (U. Washington)…
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ABA Tax Section Midyear Meeting
The ABA Tax Section Fall meeting continues today in Denver. The full program is here. Tax Profs with speaking roles today include: Administrative Practice: Taxpayer Reliance on “Formal” and “Informal” IRS Guidance — Kristin Hickman (Minnesota) Affiliated & Related Corporations: Consolidated Section 382 and the SR LY Rules: Can They Be Refined and Simplified? — Don Leatherman…
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Mason Presents Federal-State Tax Base Conformity Today at Loyola-L.A.
Ruth Mason (Connecticut) presents Delegating Up: Federal-State Tax Base Conformity at Loyola-L.A. today as part of its Tax Policy Colloquium Series: Congress uses the income tax to regulate. Because states impose their own income taxes on the federally-defined income tax base, rather than on separately determined state tax bases, states automatically import federal policies into…
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ABA Tax Section Accepting Nominations for 2012-14 Public Service Fellowships
The ABA Tax Section is accepting applications for Public Service Fellowships for 2012-2014: Applications must be received by November 1, 2011 to be considered. Applicants selected for interviews will be invited to attend the Section’s meeting in on February 16-18, 2012, and asked to participate in interviews on February 18, 2012.
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ABA Tax Section Seeks Nominations for Janet R. Spragens Pro Bono Award
The ABA Tax Section is soliciting nominations for the 2012 Janet Spragens Pro Bono Award to be presented at the January 2012 Midyear Meeting in San Diego. The award recognizes one or more individuals or law firms that have provided meritorious pro bono service in the representation of low-income taxpayers: The award may be based…
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ABA Tax Section Pro Bono Committee Launches New Website
The ABA Tax Section Pro Bono Committee has launched a new website: Vice Chairs Catherine B. Engell (DLA Piper LLP, NY, NY) and Brian David Yacker (Long Beach, CA) join me in welcoming you to the Pro Bono Committee Website! As the new Chair of the Pro Bono Committee I am hopeful that we can…
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 64, No. 2 (Winter 2011): Bradley T. Borden (Brooklyn) & Douglas L. Longhofer (Martin Pringle, Wichita, KS), The Liability-Offset Theory of Peracchi, 64 Tax Law. 237 (2011) Douglas A. Kahn (Michigan), The Taxation of a Gift or Inheritance from an Employer, 64 Tax Law. 273 (2011) Robert P. Rothman…
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ABA Tax Section Publishes Summer 2011 Issue of News Quarterly
The ABA Tax Section has published 30 News Quarterly No. 4 (Summer 2011): Points to Remember: How Pro Bono Tax Professionals Can Help Low Income Taxpayers Claim the Earned Income Tax Credit, by Kate Leifeld (Staff Attorney, Pine Tree Legal Assistance Low-Income Taxpayer Clinic, Bangor, ME), pp. 1, 21-23 Section Meeting Calendar, p. 2 From the Chair, by Charles H.…
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ABA Tax Section Submits Comments on § 355(d) Regs
The ABA Tax Section has submitted comments on § 355(d) to the IRS: In these Comments, we identify certain specific areas in which the regulations do not adequately address inconsistencies between the mechanical rules and the purposes underlying § 355(d), and we request new guidance to eliminate these inconsistencies.
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ABA Tax Section Submits Comments on 2011-12 Guidance Priority List
The ABA Tax Section has submitted this 18-page comment letter to the IRS with recommendations for the IRS’s 2011-2012 Guidance Priority List: As requested in Notice 2011-39, the ABA Section of Taxation has identified the following tax issues that we recommend be addressed through Regulations, rulings or other published guidance in 2011-2012. In each case, the name and…
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ABA Tax Section Submits Comments on Final Circular 230 Regs
The ABA Tax Section has submitted this comment letter to the IRS on the final Circular 230 regulations: The final Regulations included significant changes with regard to which there was no opportunity to comment. We believe that some of the changes may have unintended negative consequences. Specifically, the removal of references to the Office of Professional Responsibility (“OPR”) is…
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ABA Tax Section Chair Challenges Congress: Put Tax Lawyers Out of Business
Amy S. Elliott, ABA Tax Section Chair Challenges Congress to Put Tax Lawyers Out of Business, 2011 TNT 112-8 (June 10, 2011): The chair of the ABA Section of Taxation, unfazed by the prospect of losing 22% of the section’s membership — which occurred after the enactment of the Tax Reform Act of 1986 —…
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ABA Tax Section Publishes Spring 2011 Issue of News Quarterly
The ABA Tax Section has published 30 News Quarterly No. 3 (Spring 2011): Tax Link Live: What If Uncle Jim Is Undr Audit or Your Client Wants to Give You a Porsche? Ethical Issues When There Is a Personal Connection with a Client, by Lance E. Rothenberg (Hodgson & Ross, New York, NY), pp. 1, 24-25 Section Meeting…
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Jerry Cohen Receives ABA Tax Section Distinguished Service Award
N. Jerold Cohen (Sutherland Asbill & Brennan, Atlanta), former IRS Chief Counsel (1979-81), received the 2011 Distinguished Service Award from the ABA Tax Section today at the conclusion of its annual May Meeting in Washington, D.C. From the press release: “Jerry Cohen is an outstanding and committed tax lawyer,” said Charles Egerton, chair of the Section of Taxation. “His work in…
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ABA Tax Section May Meeting
The ABA Tax Section May meeting concludes today in Washington, D.C. The full program is here; Tax Profs with speaking roles today include: Foreign Lawyers Forum: Exploring the Terrain of Territorial Exemption Systems — Stephen Shay (Harvard) Low Income Taxpayers: Opening Remarks by the Chair: Kathryn Sedo (Minnesota) Low Income Taxpayers: What’s Next? — Kristin Hickman (Minnesota), Kathryn Sedo (Minnesota),…
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ABA Tax Section May Meeting
The ABA Tax Section May meeting continues today in Washington, D.C. The full program is here; Tax Profs with speaking roles today include: Banking and Savings Institutions, Financial Transactions, Insurance Companies, Investment Management and Tax Exempt Financing Committees Luncheon –Richard Harvey (Villanova) Bankruptcy & Workouts: IRS Expense Standards — Kristin Hickman (Minnesota) Court Procedure & Practice: Common Evidentiary Issues In…
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ABA Tax Section Publishes Winter 2011 Issue of News Quarterly
The ABA Tax Section has published 30 News Quarterly No. 2 (Winter 2011): Points to Remember: What Is the Value of a “Should” Opinion?, by Kathryn Morrison Sneade (Miller & Chevalier, Washington, D.C.), pp. 1, 15 Section Meeting Calendar, p. 2 From the Chair: A Renewed Call for Tax Simplification, by Charles H. Egerton (Dean, Mead, Egerton, Bloodworth, Capouano & Bozarth,…
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ABA Tax Section May Meeting
The ABA Tax Section May meeting kicks off today in Washington, D.C. The full program is here; Tax Profs with speaking roles today include: Low Income Taxpayers Representation Workshop: Communicating by Mail with the IRS — Keith Fogg (Villanova) Low Income Taxpayers Representation Workshop: Face to Face Meetings in Audits and Appeals, including CDP Hearings — Diana Leyden…
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ABA Tax Section Submits Comment Letters
The ABA Tax Section has submitted these comment letters: Proposed Regs on Domestic Series Organization Series (Apr. 29, 2011) Interim Final Rules for Group Health Plans and Health Insurance Coverage Relating to Status as Grandfathered Plan (Mar. 22, 2011) IRS Funding (Mar. 16, 2011) The Foreign Account Tax Compliance Act Offset Provisions Relating to Beneficiaries of Trusts (Feb. 14, 2011)…
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A Practitioner’s Guide to Innocent Spouse Relief
The ABA has published A Practitioner’s Guide to Innocent Spouse Relief, by Robert B. Nadler (Tennessee taxpayer Project): Thousands of Innocent Spouse claims are filed each year — this comprehensive and concisely written guide provides you with the framework for representing your client successfully. In straightforward language, the Guide takes you step-by-step through the Innocent Spouse…
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The Tax Lawyer Publishes New Issue
The Tax Lawyer has published Vol. 64, No. 1 (Fall 2010): Willard B. Taylor (Sullivan & Cromwell, New York), “Blockers,” “Stoppers,” and the Entity Classification Rules, 64 Tax Law. 1 (2010) Deborah L. Paul (Wachtell, Lipton, Rosen & Katz, New York), The Taxation of Distressed Debt Investments: Taking Stock, 64 Tax Law. 37 (2010) Shin-yi Peng (National Tsing Hua…
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ABA Tax Section Awards Two Public Service Tax Fellowships
The ABA Tax Section yesterday announced the winners of its two Public Service Tax Fellowships: Anna Tavis, scheduled to earn her J.D. from the Boston College Law School in May 2011. After graduating, Tavis will be working on tax-related matters at the South Brooklyn Legal Services in Brooklyn, N.Y. … Anna Tavis will work with the Immigrant…
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ABA Submits Comments on Tax Court’s Proposed Rules Changes
The ABA Tax Section has submitted a comment letter to the Tax Court on its proposed amendments to its rules: The Section commends the Court on the proposed amendments to its Rules and endorses the Court’s efforts to provide clarity with regard to its procedures and promote efficiency in case administration and resolution. The amendments proposed on December…
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ABA Division Adopts ‘Truth in Legal Education’ Resolution
National Law Journal, ABA Division Adopts Resolution for Truth in Law School Education: The Young Lawyers Division of the ABA has joined the chorus of voices calling for more accurate job data for would-be law students. The division on Saturday adopted the Truth in Law School Education resolution: a six-point resolution urging law schools to…