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Publications

Expedited Opt-Out Needed for OVDI Participants Who Owe No Tax
Robert B. Stack, Douglas M. Andre
Tax Notes
January 30, 2012

The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices
Patrick J. Smith
Tax Notes
January 16, 2012

Is the Anti-Injunction Act Jurisdictional?
Patrick J. Smith
Tax Notes
November 28, 2011

Charitable Lead Trusts -- A Win-Win Strategy for Donors and Charities
Brenda Jackson-Cooper
Taxation of Exempts
January/February 2010

Navigating the Research Credit
Alex E. Sadler
Tax Notes
September 2011

Overcoming Appeals' Bad Rap (quotations in article by J. Coder)
Alex E. Sadler
Tax Notes
September 2011

409A Failures: Correcting With and Without the IRS Formal Correction Programs
Rosina B. Barker
46th Southern Federal Tax Institute
September 23, 2011

DC Circuit: 'The IRS Is Not Special'
Patrick J. Smith
Tax Notes
August 30, 2011

Omissions From Gross Income and ‘Numerators and Denominators’
Patrick J. Smith
Tax Notes
July 11, 2011

Aggregate or Entity Theory of Partnerships for Currency?
John D. Bates
Tax Notes International
June 20, 2011

Life After Mayo: Silver Linings
Patrick J. Smith
Tax Notes
June 20, 2011

Carter Hood Comments on New Law Governing Foreign Trusts with U.S. Beneficiaries
H. Carter Hood
May 18, 2011

Mannella, State Farm, and the Arbitrary and Capricious Standard
Patrick J. Smith
Tax Notes
April 25, 2011

Omissions from Gross Income & Retroactivity
Patrick J. Smith
Tax Notes
April 4, 2011

Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules
John D. Bates
Tax Notes
February 14, 2011

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