New Article -- Pinch-Hitting for the IRS: Second Circuit Adopts Phanton Regulations

The University of Missouri School of Law's Business, Entrepreneurship & Tax Law Review has just published my newest Article: "Pinch-Hitting for the IRS: Second Circuit Adopts Phantom Regulations to Curb a Monster Abuse of Financial Derivatives."

It's been a few months since I posted about my last article (on PTIN user fees), but if you're interested in relatively esoteric tax topics, here is the link to this one - on my SSRN author's page.

My New Article: D.C.Circuit Upholds IRS Authority to Impose PTIN User Fees

Seems strange to have my (mostly) running blog include posts about Tax... 

But, since the Houston Business and Tax Law Journal has just published my new article, "D.C. Circuit Affirms IRS Authority to Require Practitioner Tax Id Numbers & Impose a User Fee: Montrois v. United States," why not share it?

If you are interested in the topic, here is the link to the article via my SSRN Author Page.

Law360 Interview for Article

I was interviewed for an article on the upcoming Facebook transfer pricing tax litigation.  It was published today on Law360!

Here is a link to the story: "IRS Move to Force Litigation Will Draw Lawmakers' Scrutiny" (but, unfortunately, it's behind their paywall).

today is the 97th anniversary of the sixteenth amendment - the income tax :(

on february 3, 1916, delaware became the 36th and final state necessary, to ratify the 16th amendment to the constitution of the united states. the brief, 30 word, amendment reads as follows:

The Congress shall have power to lay and collect taxes on incomes, from whatever source derived, without apportionment among the several States, and without regard to any census or enumeration.

in a nutshell, those 30 words gave the federal government authority to impose an income tax. the supreme court had, in 1895, ruled an earlier version of the income tax unconstitutional. congress, in 1909, passed the resolution that proposed the amendment and sent it on to the states for ratification. four years later it became the law of the land :(

i can't grip too much about taxes because aside from having to pay them like everyone else, i'm teaching federal income tax this semester ;p