Educational Background- LL.M. (Taxation), New York University School of Law, 2010
- J.D., New York University School of Law, 1991
- A.B., Amherst College, 1988
Area of Expertise/Research- Individual Income Taxation
- Business Taxation
- Federal Tax Policy
- Business and Commercial Law
Publications- Navigating the Split-Holding-Period Rules for Partnership Interests,
forthcoming in The Tax Lawyer, Vol. 77, No. 3 (Spring 2024) - A Review of Dorothy A. Brown’s The Whiteness of Wealth,
Journal of the American Taxation Association, Vol. 45, No. 1, Spring 2023 (pp 167-71) - Loss Cause: Developments in the Section 461(l) Excess Business Loss Rule
as of Fall 2022
in Chapter 134 of The
Partnership Tax Practice Series: Planning For Domestic and Foreign
Partnerships, LLCs, Joint Ventures & Other Strategic Alliances (Second Edition, 2023 Supplement) (Louis S. Freeman & Clifford M. Warren eds., Practicing Law
Institute 2023) - ETFs Use Section 852(b)(6) for Tax Avoidance, Not Just Tax Deferral: So Why Is This Loophole Still Open?,
75 Tax Law. 489 (2022) - Why the Antipathy Toward Business Loss Deductions Is Misguided
167 Tax Notes Federal 1863 (June 15, 2020) - The Curious Case of Section 461(l): Why This Unclear and Unwise New Rule Should Be Construed
as Narrowly as Possible, 73 Tax Law. 61 (2019)
republished
in Chapter 134 of The Partnership Tax
Practice Series: Planning for Domestic and
Foreign Partnerships, LLCs, Joint
Ventures & Other Strategic Alliances (Second Edition, 2022 Supplement)
(Louis S. Freeman & Clifford M. Warren, Eds., Practicing Law Institute 2022) - Learning the Hard Way: Deciphering the Correct Tax Treatment of Graduate Education Benefits for
University Faculty, 15 Pitt. Tax Rev. 59 (2017) (with Gregory J. Krivacek) - Tax-Efficient Structure or Tax Shelter? Curbing ETFs' Use of Section 852(b)(6) for Tax Avoidance
70 Tax Law. 537 (2017) - Testing for Regulatory Penalties: Insuring the Health of Federalism in the Age of Obamacare
119 W. Va. L. Rev. 145 (2016) - Driving Toward Certainty in UCC Financing Statements: Why Alternative A in the 2010 Amendments to
UCC § 9-503(a)(4) Is the Best Rule For Listing Individual Debtor Names
32 J. Applied Bus. Res. 1519 (2016) - Circular Argument: What is Wrong, and Right, with the Circular 230 “Covered Opinion” Regulations
2 Colum. J. Tax L. 150 (2011) - Treatment of Modified or Distressed Mortgage Loans by REITs
126 Tax Notes 1622 (March 29, 2010) - Express Warranties under the Uniform Commercial Code: Is There a Reliance Requirement?
66 N.Y.U.L. Rev. 468 (1991)
