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Reasonable Relation Reassessed: The Examination of Private Documents by Federal Regulatory Agencies, 56 NEW YORK UNIVERSITY LAW REVIEW 742 (1981).
The Taxpayer's Duty of Consistency, 46 TAX LAW REVIEW 537 (1991).
The Proposed Tax Advisor-Client Privilege: An Idea Whose Time Should Never Come, 78 TAX NOTES 1041 (1998).
Tax Profs Urge Rejection of Burden-of-Proof Shift, (with others), 78 TAX NOTES 755 (1998).
After Drye: The Likely Attachment of the Federal Tax Lien to Tenancy-by-the-Entireties Interests, 75 INDIANA LAW JOURNAL 1163 (2000).
A Residual Damages Right Against the IRS: A Cure Worse than the Disease, 88 TAX NOTES 395 (2000).
Supreme Court Tax Jurisprudence Isn’t All Bad, 87 TAX NOTES 855 (2000).
Unfinished Business on the Taxpayer Rights Agenda: Achieving Fairness in Transferee Liability Cases, 19 VIRGINIA TAX REVIEW 403 (2000).
Federal Tax Collection in the Era of Drye, 9 NEVADA LAWYER 15 (October 2001).
The IRS as Super Creditor, 92 TAX NOTES 655 (2001) .