TaxProf Blog

Editor: Paul L. Caron
Pepperdine University School of Law

Friday, August 14, 2015

Weekly Tax Roundup

Weekly Legal Education Roundup

Weekly SSRN Tax Roundup

Controversies In Tax Law: A Matter Of Perspective

Controversies in Tax Law CoverControversies in Tax Law: A Matter of Perspective (Anthony C. Infanti, ed. Ashgate 2015):

This volume presents a new approach to today’s tax controversies, reflecting that debates about taxation often turn on the differing worldviews of the debate participants. For instance, a central tension in academic tax literature - which is filtering into everyday discussions of tax law - exists between 'mainstream' and 'critical' tax theorists. This tension results from a clash of perspectives: Is taxation primarily a matter of social science or of social justice? Should tax policy debates be grounded in economics or in critical race, feminist, queer, and other outsider perspectives?

To capture and interrogate what often seems like a chasm between the different sides of tax debates, this collection comprises a series of pairs of essays. Each pair approaches a single area of controversy from two different perspectives - with one essay usually taking a 'mainstream' perspective and the other a 'critical' perspective. In writing their contributions, the authors read and incorporated reactions to each other’s essays and paid specific attention to the influence of perspective on both the area of controversy and their contribution to the debate. With contributions from leading mainstream and critical tax scholars, this volume takes the first step toward bridging the gap between these differing perspectives on tax law and policy.

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August 14, 2015 in Book Club, Scholarship, Tax | Permalink | Comments (0)

Amidst 48% Decline In 1L Class, Charleston Law School Admissions Dean Abruptly Resigns

Charleston LogoSouth Carolina Lawyers Weekly, CSOL Dean of Admissions Abruptly Resigns; John Benfield Discusses His Decision to Leave Troubled Law School:

For the first time in the history of the Charleston School of Law, longtime associate dean for admissions John Benfield was not on campus on orientation day to greet incoming students.

Benfield’s abrupt departure, announced Aug. 3, came as a surprise to students and faculty who received the news late that afternoon in an email from the school’s dean, Andy Abrams. ...

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August 14, 2015 in Legal Education | Permalink | Comments (0)

Tax Court: German Lawyer Cannot Deduct Cost Of Obtaining A U.S. J.D.

Tax Court Logo 2The Tax Court held that a German lawyer could not deduct the cost of obtaining a J.D. from the University of San Diego Law School because the education did not maintain or improve skills required in his trade or business. The taxpayer had not established himself trade or business of practicing law in the United States, and the expenses were incurred in entering into a new trade or business. The court also upheld accuracy-related penalties under § 6662(a). O'Connor v. Commissioner, T.C. Memo. 2015-155 (Aug. 12, 2015).

August 14, 2015 in Legal Education | Permalink | Comments (1)

The IRS Scandal, Day 827

IRS Logo 2 Politico, Lerner Slammed ‘Evil and Dishonest’ GOP Inquisitors:

At the height of the scandal over the IRS’ handling of political nonprofits, Lois Lerner privately let loose at her Republican tormentors, saying she invoked the Fifth Amendment because they had been “evil and dishonest” and accusing them of “hate mongering.”

A POLITICO examination of thousands of pages of emails and other material recently released by the Senate Finance Committee found previously unreported comments from Lerner, the central figure in the controversy, on everything from the inability of career IRS agents to handle “the sensitive stuff” to her views on the fiscal cliff.

When she was under investigation by Congress, she offered a blistering critique of her inquisitors. In a March 6, 2014, email, Lerner told a friend: “They called me back to testify on the IRS ‘scandal,’ and I too[k] the 5th again because they had been so evil and dishonest in my lawyer’s dealings with them.” ...

Republicans see a clear link between Lerner’s comments and the agency’s actions; Democrats don’t. The lack of ironclad proof that agents deliberately targeted groups because of political bias — or that they didn’t — means neither party can separate itself from the narrative it has held to for two years.

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August 14, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

Thursday, August 13, 2015

Tax Court Petition: Can Boston Bruins (And Other Pro Sports Teams) Deduct 100% Of Meal Expenses At Away Games; Is Hotel A Team's 'Business Premises'?

BruinBloomberg BNA, Boston Bruins Raise Controversy by Arguing That Meals Are Deductible, Team Is "World Class", by Syd Gernstein:

[A] recent case filed in the U.S. Tax Court, Jacobs v. Commissioner, No. 19009-15 (petition filed July 27, 2015), caught my eye. 

At issue is whether the Boston Bruins hockey club may deduct 100% of the costs it incurred to provide its players and staff with meals while travelling to away games. The case poses the IRS and Tax Court with some fairly interesting questions concerning the deductibility of employee fringe benefits. ...

And, although it is not clear on the face of the Bruins’ Tax Court petition, I think it is this employer operated eating facility exception that the Bruins are going to rely on to argue that the meals are 100% deductible.

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August 13, 2015 in New Cases, Tax | Permalink | Comments (5)

Tax Lawyer Charged With Kidnapping, Attempted Murder

Tax LawyerAbove the Law, Attempted Murder Charge Puts A Real Crimp In Man’s Tax Law Practice:

A North Carolina tax attorney earned a suspension over some criminal charges he faces in neighboring South Carolina. Is it anything serious? Depends on how you feel about kidnapping and attempted murder.

So… yeah, pretty serious.

Tax attorneys, man. Why is it always the quiet ones who get in this kind trouble?

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August 13, 2015 in Tax | Permalink | Comments (0)

University Of Auckland Seeks To Hire A Tax Prof

AucklandThe University of Auckland, Faculty of Business and Economics, seeks to hire a Professor of Taxation in the Department of Commercial Law:

The position is intended for candidates with leadership experience, a relevant PhD and an international research portfolio. The candidate must demonstrate a strong commitment to excellence in research in taxation and will be able to demonstrate excellence in the teaching at undergraduate and postgraduate levels. Evidence of leadership in research, a significant international standing, high quality teaching and supervision at PhD level is required. Ideally, in addition to research and teaching in taxation law, the candidate would also be researching, teaching and supervising in company law.

The main purpose of this position is to:

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August 13, 2015 in Legal Education, Tax, Tax Prof Jobs | Permalink | Comments (0)

Merritt: Kudos To California's 15-Credit Experiential Learning Requirement

California State Bar (2014)Deborah Jones Merritt (Ohio State), Kudos to California:

In February 2012, the California Bar Association appointed a task force to “examine whether the State Bar should develop a regulatory requirement for a pre-admission competency training program.” The group, dubbed the “Task Force on Admissions Regulatory Reform” (TFARR), oversaw hearings, deliberations, and consultations with key constituencies. It issued an initial report in 2013, which was adopted by the bar association’s board of trustees, then held a second round of hearings and deliberations to refine the recommendations for implementation.

That second report has been approved by the bar and awaits action by the California Supreme Court. What’s noteworthy about all of this? If approved, law graduates seeking to join the California bar will have to meet three new requirements. Law schools around the country will also have to help their California-bound students satisfy the first requirement: demonstrating completion of “15 units of practice-based, experiential coursework.”

I see both positives and negatives in the California proposal but, on balance, it’s a strong step forward. The proposal is a lengthy one, so I will explore it in several posts. To start, here are the features I find most appealing. ...

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August 13, 2015 in Legal Education | Permalink | Comments (0)

Republicans Seek To Ban Unions For IRS Employees

NTEUWashington Post, Republican Plan to Eliminate IRS Union, As It Elects New Leadership, Could Threaten Federal Unions Generally:

Republicans have an unwelcome gift for the retiring president of the National Treasury Employees Union (NTEU) and its newly elected officers.

A proposal by Senate Finance Committee Republicans would prohibit unions at the Internal Revenue Service. That would cut the labor organization’s membership in half.

If this attack is successful it would decimate NTEU and leave IRS staffers without union representation. More that than, it would weaken federal unions generally by making them all vulnerable to a similar assault.

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August 13, 2015 in IRS News, Tax | Permalink | Comments (9)

Texas Wesleyan Law Grads Sue Texas A&M Over Alumni Status

Texas A&M Law Logo (2015)Houston Chronicle, Texas Wesleyan Law Grads Sue A&M Over Alumni Status:

In one news release, for instance, university officials note that A&M law students have provided more than 120,000 hours of free legal services valued at more than $2.4 million.

But much of that work was done by alumni who earned degrees from Texas Wesleyan School of Law in Fort Worth, before A&M purchased the school in 2013. A&M did not previously have a law school.

While A&M has taken credit for their work, the school won't recognize them as A&M alumni, dozens of the graduates argue in a class-action lawsuit filed Tuesday. They contend the refusal of new degrees or alumni status makes it difficult to apply for jobs or take bar exams. ...

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August 13, 2015 in Legal Education | Permalink | Comments (1)

Revisions To ABA Accreditation Standards

ABA Logo 2Memorandum From Barry A. Currier (Managing Director of Accreditation and Legal Education), Adoption and Implementation of Revised Standards and Rules for Approval of Law Schools

At its meetings in June and July 2015, the Council approved changes to the ABA Standards and Rules of Procedure for Approval of Law Schools. The changes had been circulated for Notice and Comment and public hearings were held on April 30 and July 16, 2015. The following amended Standards and Rules of Procedure became effective upon concurrence by the ABA House of Delegates at its meeting on August 3-4, 2015:

  1. Definition (17) and Standard 106 [Separate Locations and Branch Campuses]
  2. Standard 105 [Acquiescence for Major Change in Program or Structure] and Rule 29(a) [Application for Acquiescence in Major Change]
  3. Standard 304 [Simulation Courses and Law Clinics]
  4. Standard 305(e)(6) and Interpretation 305-3 [Field Placements and Other Study Outside the Classroom]
  5. Standard 311(a) and Interpretation 311-1 [Academic Program and Academic Calendar]
  6. Standard 311(f) [Academic Program and Academic Calendar] and Standard 308(a) [Academic Standards]
  7. Interpretation 311-4 [Academic Program and Academic Calendar]
  8. Standard 502(b)(2) [Educational Requirements]
  9. Standard 505(b) [Granting of J.D. Degree Credit for Prior Law Study]
  10. Rule 27 [Application for Provisional or Full Approval] and Rule 28 [Reapplication for Provisional or Full Approval]
  11. Rule 29(d-g) [Application for Acquiescence in Major Change]
  12. Rule 30 [Major Changes Requiring a Reliable Plan]]

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August 13, 2015 in Legal Education | Permalink | Comments (0)

The IRS Scandal, Day 826

IRS Logo 2 Investor's Business Daily op-ed, Jailtime For IRS' Political Hacks:

Corruption: After a year's stalling by the IRS, the Senate Finance Committee has released its bipartisan report, denouncing the tax-collection agency's partisanship and incompetence. When are these people going to jail?

The Senate report wasn't entirely satisfactory, given that its criticism was primarily in the compromise language of "gross mismanagement" to describe the agency's targeting of Tea Party dissident groups.

Using legal technicalities to silence and repress political dissent under the color of the nation's most feared enforcement agency isn't mismanagement. It's a crime.

It's incompatible with democracy and it shatters public confidence in the rule of law. It's the very crime the State Department is now condemning in Venezuela: the use of legal technicalities to halt popular opposition candidates from running for office. Until now, this kind of activity has had no precedent in our country, and it must be stopped before it becomes the standard.

This is far from mere incompetence or gross mismanagement. It was a highly competent operation to silence dissent. Yet no one has been sanctioned or punished, despite there being laws on the books dating back to the beginning of a professional civil service, that forbid and punish partisan motives in what should be impartial law. Already some observers believe the IRS swung the last election for the Democrats with these activities.

Not only did the IRS target Tea Party groups with unconscionable delays and intrusive questions, it went for their families, too. Young Bristol Palin learned yesterday that just being the daughter of former Alaska Gov. and Tea Party favorite Sarah Palin put her in the IRS' sights. Sarah Palin's father was targeted, too.

The agency also obstructed justice, first falsely claiming that its illegal targeting was only the work of rogue agents in its Cincinnati office. Then, as that lie fell apart, IRS moved to destroy evidence in the thousands of missing emails on IRS tax exempt organizations chief Lois Lerner's computer. Conveniently for them, it was declared lost forever in a hard drive crash — until it wasn't.

Now it's relying on its allies in the Senate and among anti-Tea Party Democrats in the House for cover, having them declare it incompetence, not a crime.

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August 13, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (4)

Wednesday, August 12, 2015

McGinnis & Schanzenbach: It's Time To End Faculty Tenure

TenureWall Street Journal op-ed:  College Tenure Has Reached Its Sell-By Date, by John O. McGinnis (Northwestern) & Max M. Schanzenbach (Northwestern):

Wisconsin Gov. Scott Walker has come under fire from academics nationwide for calling on his state’s Board of Regents to reconsider the scope of tenure in its university system. Evaluations of faculty members “should be based on performance,” he said this summer, “they should be based on merit.”

With state universities struggling to keep up with rising costs and technological change, one would expect administrators and educators to at least consider proposals that would save money and encourage change.

Strong tenure protections impose significant costs on higher education. Although these costs were voluntarily created when universities adopted tenure in the first half of the 20th century, they were markedly increased in 1994 when Congress prohibited mandatory retirement for tenured faculty.

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August 12, 2015 in Legal Education | Permalink | Comments (1)

NY Times: Let's Keep The Cadillac Tax

New York Times editorial, Keep the Tax on High-End Health Plans:

Congress is under pressure to repeal an impending tax on the so-called Cadillac health plans offered by many employers. Scores of legislators from each party have endorsed separate bills to repeal it, and candidates for office, pressed by lobbyists from labor unions, business groups and insurers, may join the call for repeal. The tax should probably be adjusted by Congress to eliminate inequities, but outright repeal would be a mistake that would undermine the viability of the Affordable Care Act.

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August 12, 2015 in Tax | Permalink | Comments (0)

Barton: The Upside Of The Law School Crisis

GlassFollowing up on my previous post (here and here):  Chronicle of Higher Education,  The Upside of the Legal Profession's Crisis, by Benjamin H. Barton (Tennessee); author, Glass Half Full The Decline and Rebirth of the Legal Profession (Oxford University Press, 2015)):

Four different interlocking trends are squeezing American lawyers and law schools. First, after a 50-year ride of growth in size and profits, corporate law-firm revenues have slowed since 2008.Businesses have grown tired of paying ever-higher fees and are using insourcing, outsourcing, and computerization for more-straightforward legal work, though they have continued to pay more for true bet-the-company transactional and litigation work.

Second, computerization has started to squeeze ordinary lawyers. LegalZoom, Rocket Lawyer, and others are horning in on traditional areas of practice, like drafting incorporation papers and wills, and are also offering inexpensive legal-advice plans. Right now they are reaching only low-hanging fruit by offering simple legal documents or monthly legal-advice plans. As they grow in size, complexity, and acceptance, price competition will further stiffen. ...

Third, courts and legislatures have reined in litigation since the 1980s. Tort reform has limited class actions, damages, and fees, and tort law is less lucrative for the lawyers involved.

Last, there has been a 30-year decline in earnings for small firms and solo practitioners. ...

In 2008 hard times for corporate law firms finally brought public attention to the employment numbers for law graduates, and applications and attendance at law schools have fallen steeply since 2010. ... [T]roubled law schools will risk disaccreditation by admitting anyone they can and radically cutting costs rather than actually closing their doors. This could mean closing the law library or replacing the bulk of the tenured faculty with adjuncts. It would be inexpensive to run a skeleton law school that has few administrators and is taught by adjunct faculty. The question would then shift to how the A.B.A. might respond. It has never disaccredited a fully accredited American law school, and the legal and public-relations ramifications of such a move are unclear. ...

I think that after some rough sledding, the public, the profession, and the professoriate will all benefit from the law’s transformation. ...

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August 12, 2015 in Book Club, Legal Education | Permalink | Comments (6)

Oregon Symposium: Disruptive Innovation In Law And Technology

DisruptiveSymposium, Disruptive Innovation in Law and Technology, 93 Or. L. Rev. 831-934 (2015):

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August 12, 2015 in Legal Education, Scholarship | Permalink | Comments (2)

Graetz: The End Of Energy

GraetzMichael Graetz (Columbia), The End of Energy The Unmaking of America's Environment, Security, and Independence (Chapters 11 & 12) (MIT Press, 2011):

With the permission of MIT Press, this document includes Chapters 11 and 12 from my 2011 book, The End of Energy: The Unmaking of America’s Environment, Security, and Independence. These two chapters discuss some of the history and merits of taxes, subsidies, and regulation (including cap and trade) as mechanisms to implement policies to curb greenhouse gases. In light of the renewed interest in and discussion of command and control regulations and carbon taxes, these chapters may be useful to readers who do not have the book. The bibliographic material relating to these chapters is contained in the book and has been omitted here.

Description of the book:

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August 12, 2015 in Book Club, Scholarship, Tax | Permalink | Comments (1)

WSJ: Number Of Academic Paper Co-Authors Skyrockets In Bid To Goose Citation Ranking — The Proliferation Of 'Kilo-Authors'

WSJWall Street Journal, How Many Scientists Does It Take to Write a Paper? Apparently, Thousands:

A Frenchman named Georges Aad may have the most prominent name in particle physics.

In less than a decade, Dr. Aad, who lives in Marseilles, France, has appeared as the lead author on 458 scientific papers. Nobody knows just how many scientists it may take to screw in a light bulb, but it took 5,154 researchers to write one physics paper earlier this year—likely a record—and Dr. Aad led the list.

His scientific renown is a tribute to alphabetical order. Almost every paper by “G. Aad et al.” involves so many researchers that they decided to always list themselves in alphabetical order. ...

[T]here has been a notable spike since 2009 in the number of technical reports whose author counts exceeded 1,000 people, according to the Thomson Reuters Web of Science, which analyzed citation data. In the ever-expanding universe of credit where credit is apparently due, the practice has become so widespread that some scientists now joke that they measure their collaborators in bulk—by the “kilo-author.” ...

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August 12, 2015 in Legal Education, Scholarship | Permalink | Comments (1)

Barnhizer: The Warrior Lawyer

WarriorDavid Barnhizer (Cleveland State), The Warrior Lawyer II: Using The Art of War and A Book of Five Rings to Gain Victory Through Disciplined Strategy (2015):

The force that ties all the pieces of law practice together into a coherent system is strategy—which can be understood as the ability to both plan and take action to achieve desired goals, or to at least significantly increase the probability of achieving a client’s goals. One of the main reasons for studying strategy is that it improves our ability to evaluate, diagnose, estimate risks and costs and resolve the problems and opportunities our clients bring to us. Sun Tzu's Art of War and Musashi's Book of Five Rings offer a unique strategic language. Sun Tzu’s Art of War is one of history's most widely read works on strategy. It has had significant influence on military strategy in Asia, including Japan and China. Sun Tzu and Musashi are like puzzle boxes with multi-layered expositions of strategic understanding the strategist can return to again and again. There is no finality to the insights. Musashi observes: "Really skillful people never get out of time, and are always deliberate, and never appear busy." This is the essence of the master strategist, whatever the discipline. The strategist is always in control of self. The Way of strategy offered by the combination of Sun Tzu's and Musashi's strategic thought is a methodology of greater awareness and effectiveness. Their insights as applied to the practice of law enable the strategist to perceive the world more sharply, extensively, and deeply.

August 12, 2015 in Book Club, Legal Education | Permalink | Comments (8)

The IRS Scandal, Day 825

IRS Logo 2 Forbes:  Bristol Palin At Heart Of IRS Scandal - Who Knew?, by Peter J. Reilly:

What Does Bristol Plain Have To Do With The IRS Scandal?
The section of the report where this revelation is included is titled “Lois Lerner’s Management of the EO Examination Unit Reveal Her Political Bias Against Conservative Organization”. In the subsection “Lois Lerner Intervened in Audit Decisions Involving Political Organizations” we have

Teen Pregnancy Organization Affiliated With Bristol Palin
Another example of Lerner’s interest in conservative organizations occurred in 2011, when Lerner considered opening an audit of a group with ties to Bristol Palin.  There were reports that Palin received $332,500 in compensation from the Candie’s Foundation, a nonprofit organization that seeks to prevent teen pregnancy. Upon receiving an article containing this information, Lerner took the initiative to ask her senior advisors if the IRS should open an audit of the organization:

“Thoughts on the Bristol Palin issue? I’m curious that a [private foundation] can pay any amount to someone who is not a [disqualified person]? It is a [private foundation] right? Even if it were a [public charity] – would that be private benefit – what are the consequences? I’m asking because I don’t know whether to send to Exam as a referral”.

Lerner’s willingness to act on this particular news article – among many that reached her inbox each day – shows that she was paying close attention to conservative politicians and organizations. In its review of nearly 1,500,000 pages of documents provided by the IRS, Majority staff did not find any instances where Lerner referred a progressive organization for audit based on a news article.

Whatever her faults might be Lois Lerner is up on the intersection of pop culture with tax law, although there is some indication that she is either not a careful reader or discerning in her choices of where to read, because she clearly did not grasp what was going on. It seems that her inference was that the Palin clan had started a teen pregnancy foundation, since they had some experience with it. That was not at all what had happened.  You actually don’t have to go beyond forbes.com to get the story behind the story. ...

What Does This Say About Lois Lerner?
I think the Republicans have busted her on this one.  That email really is evidence of reflexive anti-conservatism. Certain liberals have a Pavlovian response to the Palin clan. The only thing that gets them to jump up and bark better is mention of the Koch brothers, but there does not seem to be anything funny about them.  Conservatives seem to have more triggers – Jesse Jackson, Hillary Clinton, Benghazi, but the same principle is at work.

What Does This Say About The Scandal?
So what we have is a reflexive anit-conservative appointed to head the IRS Exempt Group during the Bush administration by an IRS Commissioner appointed by Bush.  Is it possible that the big money Republicans figured that they had the IRS exempt group outgunned, but that a reflexive anti-conservative in that position would be tough on the more conservative part of the party. The other thing that the report mentions is that during the whole period of the scandal no audits of exempts were initiated over the political spending issue.  So the established dark money organizations were let off scot-free.  All the grief went to the Tea Party insurgents who were least able to cope with it.

Remember Lois Lerner Is Not The IRS
The other thing that comes out in the report is that Lois Lerner did not like the line IRS people who were doing the mundane work of the agency and they did not feel supported by her.

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August 12, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (3)

Tuesday, August 11, 2015

Accounting Hiring, Enrollments Are At Record Levels

Journal of Accountancy, Hiring and Enrollments Reached Record Highs Last Year:

Unlike many in their Millennial cohort who face continued underemployment, accounting graduates find themselves in high demand from employers. Top students are often recruited, offered jobs during or after their internships, and enticed with signing bonuses.

According to the AICPA report Trends in the Supply of Accounting Graduates and the Demand for Public Accounting Recruits, hiring at public accounting firms jumped 7% to reach record levels in 2013–14. Ninety-one percent of all firms said they expect to hire accounting graduates at the same or higher levels in 2015.

CPA

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August 11, 2015 in Tax | Permalink | Comments (2)

Harvard Law Prof Larry Lessig Mulls Presidential Bid, Would Resign After Passage Of Campaign Finance Reform And Let VP Bernie Sanders Or Elizabeth Warren Take Over

LessigHuffington Post:  Why I Want to Run, by Larry Lessig (Harvard):

Today I announced the formation of a committee to explore my entering the Democratic Primary for President. By Labor Day, I will decide whether a run makes sense.

I want to run. But I want to run to be a different kind of president. "Different" not in the traditional political puffery sense of that term. "Different," quite literally. I want to run to build a mandate for the fundamental change that our democracy desperately needs. Once that is passed, I would resign, and the elected Vice President would become President.

Wall Street Journal Law Blog, Harvard’s Lawrence Lessig Weighs Campaign for One-Day Presidency:

The Harvard law professor, who says his top priority is to “unrig this rigged system,” is launching an unconventional bid to be what he calls a “referendum president.”

His idea is straightforward: If elected, Mr. Lessig would take action to overhaul campaign-finance laws and end what he describes as voter suppression and partisan gerrymandering. Then — perhaps even after a single day, though he acknowledges that’s “hopeful”—he would step aside and let his vice president lead. He says he would consider Democratic candidate Bernie Sanders or Massachusetts Sen. Elizabeth Warren—who has repeatedly said she does not plan to run—to join him on the ticket.

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August 11, 2015 in Legal Education, Political News | Permalink | Comments (5)

Hillary Clinton And Bernie Sanders Want To Use The Tax Code To Weaken Wall Street

Wall StreetVox:  Hillary Clinton and Bernie Sanders Want to Use the Tax Code to Weaken Wall Street, by Ezra Klein:

In 2008, candidate Barack Obama's tax policies sought to achieve the normal ends of Democratic tax policy: Fund the basic operations of the federal government, give more money to the poor and middle class, and take more money from the rich. That is, for the most part, what we expect Democratic tax plans to do.

But the tax plans Hillary Clinton and Bernie Sanders have unveiled are more radical than that. Yes, they raise money to fund government operations, and sure, they redistribute wealth a bit. But their real aim is far more ambitious: They want to change the way the economy actually works.

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August 11, 2015 in Political News, Tax | Permalink | Comments (2)

Amidst Turmoil, LSU Law School Appoints Interim Co-Deans

The 69 Most-Cited Law Faculties

Gregory C. Sisk (University of St. Thomas) et al.,  Scholarly Impact of Law School Faculties in 2015: Updating the Leiter Score Ranking for the Top Third:

This study explores the scholarly impact of law faculties, ranking the top third of ABA-accredited law schools. Refined by Professor Brian Leiter, the “Scholarly Impact Score” for a law faculty is calculated from the mean and the median of total law journal citations over the past five years to the work of tenured members of that law faculty. In addition to a school-by-school ranking, we report the mean, median, and weighted score, along with a listing of the tenured law faculty members at each ranked law school with the ten highest individual citation counts.

1.   Yale
2.   Harvard
3.   Chicago
4.   NYU
5.   Stanford
6.   UC-Irvine
7.   Columbia
8.   Duke
9.   Vanderbilt, UC-Berkeley
11.  Pennsylvania
12.  Northwestern
13.  Cornell, UCLA
15.  Michigan, Georgetown
17.  Virginia, George Washington
19.  Minnesota
20.  Texas
21.  George Mason, Washington University, Boston University
24.  UC-Davis
25.  Case Western, Notre Dame
27.  Illinois, Emory
29.  Cardozo, Arizona, Colorado, Ohio State
33.  North Carolina, Brooklyn
35.  Indiana, Utah, Fordham, San Diego
39.  Florida State, Arizona State, USC, St. Thomas, Iowa
44.  UC-Hastings, William & Mary, Maryland
47.  BYU, Hofstra, Washington & Lee
50.  UNLV, Pittsburgh
52.  Temple, Wake Forest, Florida, Chicago-Kent, Alabama
57.  Georgia, Houston, Loyola-L.A., American, Boston College
62.  Missouri, Toledo
64.  DePaul, Rutgers-Camden, Kansas, Tulane, Hawaii, San Francisco

Here are the 16 Tax Profs among the 10-most cited faculty at the Top 69 law schools:

2.   Harvard:  Louis Kaplow
15.  Michigan: Reuven Avi-Yonah
19.  Minnesota:  Kristin Hickman
24.  UC-Davis:  Dennis Ventry
29.  Cardozo: Ed Zelinsky
33.  North Carolina:  Gregg Polsky
35.  Indiana:  Leandra Lederman; San Diego:  Vic Fleischer
39.  USC:  Ed Kleinbard, Ed McCaffery
47.  BYU:  Cliff Fleming
52.  Temple:  Nancy Knauer; Chicago-Kent: Evelyn Brody
57.  Loyola-L.A.:  Ellen Aprill
64.  Tulane: Marjorie Kornhauser; San Francisco: Joshua Rosenberg

Several law faculties achieve Scholarly Impact Scores well above the rankings reported by U.S. News:

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August 11, 2015 in Law School Rankings, Legal Education, Scholarship, Tax | Permalink | Comments (8)

Federal Judge Rejects LSAC's Challenge To Expert Panel's Disability Accommodation Plan For LSAT

LSAT (2015)National Law Journal, Magistrate Upholds LSAT Disability Accommodation Plan:

A federal magistrate judge has largely upheld a set of procedures intended to make it easier for people with disabilities to qualify for accommodations when taking the Law School Admission Test.

Judge Joseph Spero of the U.S. District Court for Northern District of California on Friday issued a 44-page opinion validating nearly all of an expert panel’s recommended changes to the way the Law School Admission Council weighs requests for accommodations. [Department of Fair Employment and Housing v. Law School Admission Council, No. 12-cv-01830 (N.D. Cal. Aug. 7, 2015)].

They include:

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August 11, 2015 in Legal Education | Permalink | Comments (0)

CRS: The Federal Tax Treatment Of Married Same-Sex Couples

CRS LogoCongressional Research Service, The Federal Tax Treatment of Married Same-Sex Couples (R43157) (July 30, 2015):

This report provides an overview of the federal tax treatment of same-sex married couples, with a focus on the federal income tax. Estate tax issues are also discussed. The administration of federal tax laws for married same-sex couples changed as a result of the U.S. Supreme Court ruling in United States v. Windsor in 2013, striking down Section 3 of the Defense of Marriage Act. The administration of federal tax laws was not affected by the June 26, 2015, ruling in Obergefell v. Hodges. Obergefell struck down state bans on same-sex marriage, holding that all states must both permit same-sex couples to marry in their states and recognize same-sex marriages that were formed in other states. While it did not change the administration of federal income tax laws, the Obergefell decision may affect the number of same-sex couples who decide to marry (and hence the number of federal and state tax returns filed by married couples). Analysis of changes to individuals’ state tax liabilities resulting from the Obergefell decision is beyond the scope of this report; however, state tax changes may ultimately affect federal tax liabilities for those couples who itemize deductions on their federal returns.

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August 11, 2015 in Gov't Reports, Tax | Permalink | Comments (0)

The IRS Scandal, Day 824

Monday, August 10, 2015

The Tax Consequences Of 'Bug Bounties'

BUG bOUNTYCNN, Hackers Score 1 Million Miles for Helping United Find Security Bugs:

Two hackers scored an unusual bounty of one million frequent flyer miles for identifying holes in United Airlines' security system. ...

Such awards, known as a "bug bounties" are paid to any hacker that can help United identify a problem with its system. Many companies and security firms offer bug bounties, including Google and Facebook, but United says it's the first airline to so.

[O]ffering frequent flyer miles instead of cash helped get the hacker community's attention.

Bug Tweet

DansDeals.com, The Tax Consequences Of Helping United Fix Bugs On Their Site:

Surprisingly none of the news outlets covered the tax implications of being awarded 1,000,000 miles.

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August 10, 2015 in Tax | Permalink | Comments (1)

WSJ: Inversion Deals Retain Their Tax Allure

InversionWall Street Journal, Inversion Deals Retain Their Allure:

Companies continue to leave the U.S. through inversion deals, nearly a year after the Treasury Department clamped down on the tax-fueled mergers.

Two U.S. companies Thursday announced plans to move overseas through inversions, bringing the year’s tally of proposed inversions to six. A total of 10 inversions, which allow firms to lower their corporate tax rates by buying foreign targets, were done in 2014, according to data provider Dealogic.

CF Industries Holdings Inc., a Deerfield, Ill.-based fertilizer maker, said it would merge with parts of Netherlands-based OCI NV in a deal valued at $6 billion as well as the assumption of $2 billion in debt. Atlanta-based Coca-Cola Enterprises Inc., meanwhile, announced a three-way merger of European bottling operations to create a company with $12 billion in sales.

Both companies will set up new headquarters in the U.K., where the corporate tax rate is around 20%, compared with about 35% in the U.S.

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August 10, 2015 in Tax | Permalink | Comments (1)

Colleges Opposed To Gay Marriage Fear IRS Retribution

White House Same Sex MarriageThe Hill, Colleges Opposed to Gay Marriage Fear IRS Retribution:

The IRS says it has no plans to target the tax exemption of colleges that oppose same-sex marriage, but supporters of those institutions fear it could be a temporary reprieve.

John Koskinen, the IRS commissioner, made it clear at a Senate hearing late last month that his agency wouldn’t release any new rules going after religious colleges’ tax exemption during his last two-and-a-half years in office.

Conservatives had grown increasingly worried about that proposition after the Obama administration’s solicitor general said that the tax exemption of educational institutions that oppose same-sex marriage could be an issue during Supreme Court arguments this year.

“At this time, there is no basis for us to revisit tax-exempt status on that ground,” Koskinen told Sen. Mike Lee (R-Utah) at a Senate Judiciary subcommittee hearing. “It is our view right now in terms of the overall lay of the land that there’s no basis for us at this point to make any different change in our review policies, our exam policies.”

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August 10, 2015 in Tax | Permalink | Comments (0)

A Death In Our Church Family

ShawnAl Sturgeon, Dean of Students at Pepperdine and one of my favorite people in this business, has written this moving tribute on the death of a member of our church family:

Reverend James Forbes once said that nobody gets into heaven without a letter of reference from someone who is living without, and for many in our congregation Shawn was the first person known well enough to approach for a recommendation.

Shawn’s struggles left him without a home, something he openly shared on stage via microphone, but he destroyed the homeless stereotype. He didn’t look/smell/act/speak like anything in the brochures. Shawn hugged us, swapped stories with us, handed us bulletins at the front door, shared his life with us, and knew and remembered us by name.

The news of Shawn’s death took some wind out of me. I have experienced the loss of many people and as a former professional minister had a front row seat to the terrible specter of death on far too many occasions, but to me there is something different about losing Shawn. The loss is not inexplicable or particularly unusual, but it is its own special kind of sad.

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August 10, 2015 | Permalink | Comments (0)

Ninth Circuit Gives Unmarried Couples Double The Mortgage Interest Deduction Available To Married Couples

Tax Court Logo 2A split Ninth Circuit panel on Friday reversed the Tax Court and held, contrary to the IRS's position, that the § 163(h)(3) limitations on the deductibility of mortgage interest ($1 million of acquisition indebtedness plus $100,000 of home equity indebtedness) are applied on a per-taxpayer basis (for a total of $2.2 of mortgage debt), as contended by celebrity psychiatrist Charles Sophy and his domestic partner, Bruce Voss, who owned homes in Beverly Hills and Rancho Mirage, California, as joint tenants.  Voss v. Commissioner, Nos. 12-73257 & 12-73261 (Aug. 7, 2015). (The Tax Court had upheld the IRS's position that §163(h)(3) applies on a per-residence basis (and thus limited to $1.1 of mortgage debt.  Sophy v. Commissioner, 138 T.C. 204 (2012).)

Judge Ikuta dissented:

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August 10, 2015 in New Cases, Tax | Permalink | Comments (8)

The Suicide of the Liberal Arts

Liberal ArtsWall Street Journal op-ed:  The Suicide of the Liberal Arts, by John Agresto (former president, St. John’s College):

[T]his tension between getting an education—specifically a liberal arts education—and studying something practical or simply going off to work was hardly unique to me. Yes, this “liberal education” is worth something. But so is making, doing, building and working—so is knowing other good stuff. And that tension—between the practical and productive on one hand, and the intellectual and more academic or cultural on the other—has been and still is at the heart of America’s historical ambivalence toward liberal education.

Parents often still ask, “But what exactly does one do with a major in philosophy, classics, lyric poetry, women’s studies, or the literature of oppression and rebellion?” With jobs so scarce, students ask themselves the same questions.

Still, it’s not simply the high cost of higher education, or their supposed uselessness, that has buried today’s liberal arts. More important, professors in the liberal arts have over-promised, or promised wrongly. We have these lovely phrases, like making our students “well-rounded,” that are more or less just words. Are those who study medicine or nursing not “well-rounded”? Are those who major in film studies or contemporary “lit crit” more intellectually worthy than those who study economics and finance?

Often enough over the years I’ve heard my humanities confreres say that a liberal education makes us finer people, more sensitive, more concerned, more humane, even more human. Pretentious shibboleths such as these, expressed in our egalitarian age, are an excellent way to lose one’s audience. And that’s exactly where the liberal arts are today.

Liberal arts has not been killed by parental or student philistinism, or the cupidity of today’s educational institutions whose excessive costs have made the liberal arts into an unattainable luxury. In too many ways the liberal arts have died not by murder but by suicide.

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August 10, 2015 in Legal Education | Permalink | Comments (1)

LA Times: California Bar Urged To Require Unaccredited Law Schools To Disclose Graduation, Dropout Rate

California State Bar (2014)Los Angeles Times, State Bar Urged to Require Unaccredited Law Schools to Disclose Graduation, Dropout Rate:

Legislators and legal experts are urging California bar officials to require the state's unaccredited law schools to be more transparent to give prospective students a better idea of their chances of becoming an attorney.

The proposed changes, which include the disclosure of such information as dropout rates and alumni employment, would mirror similar changes made by nationally accredited law schools such as UCLA and USC.

The proposals come after a Times investigation last month showed that nearly 9 out of 10 students at those schools dropped out before their final year of study. About 1 in 5 unaccredited law school students who finish these programs pass the bar each year, according to state statistics.

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August 10, 2015 in Legal Education | Permalink | Comments (0)

The IRS Scandal, Day 823

IRS Logo 2Forbes:  The Republicans Might Be Right About IRS Commissioner John Koskinen, by Jeremy Scott:

On July 27, House Oversight and Government Reform Committee Chair Jason Chaffetz said President Obama should remove IRS Commissioner John Koskinen, and he made it clear that if the president doesn’t act, Congress could consider contempt charges and even impeachment. On the one hand, Chaffetz’s threats seem like just the latest escalation in a long conflict between congressional Republicans, the IRS, and the White House. But the reality is that Koskinen has so lost the confidence of the lawmakers in charge of his budget and oversight that it might be time for yet another change of leadership at the agency.

The call for Koskinen’s removal comes on the heels of a revelation that the IRS destroyed 422 backup tapes containing 24,000 e-mails from former IRS exempt organizations director Lois Lerner three weeks before Koskinen testified before Congress and promised to deliver all of Lerner’s e-mails to investigators. ... Koskinen probably didn’t know about the destruction of the tapes before he testified to Congress. But the loss of the tapes is the latest in a pattern of questionable IRS practices throughout this entire process. It disturbingly mirrors IRS officials’ testimony before Congress after the 2010 elections, assuring lawmakers that conservative groups were not being targeted when in fact the IRS admitted in 2013 that they were. It was also not clear in 2010 who knew what and when, but it was fairly clear that the testimony given to lawmakers didn’t accurately describe what was going on at the Service. Acting IRS Commissioner Steven Miller was asked to resign by Obama after the scandal became known. Was Miller really more responsible for the initial targeting than Koskinen has been for the IRS’s handling of the crisis since December 2013?

Engaging with House Republicans can be tough. They are out to score political points and have been determined to derail the Obama administration since they retook the chamber in 2010. But it’s the IRS commissioner’s job to deal with lawmakers, and Koskinen was supposed to improve the agency’s disjointed response to the EO scandal. Instead, he has doubled down on its stonewalling. He has been unresponsive, evasive, and even combative at hearings. House Ways and Means Chair Paul Ryan, hardly a conservative hothead, has flat-out accused the commissioner of lying. The commissioner’s relationship with the majority party has steadily worsened since he took office.

The IRS needs a leader who can restore its morale, fix the management mess that led to the EO scandal in the first place, and convince Congress that the agency needs and can be trusted with a bigger budget. Even if you think Koskinen can succeed at the first two (and that’s far from clear), there is no way he can accomplish the last. And the IRS can’t settle for two out of three right now. That’s why Koskinen is no longer the right leader for the IRS. Obama should do the same thing to Koskinen that he did to Miller, and he should prioritize working with Republicans to make sure they support his pick for the next commissioner.

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August 10, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (2)

TaxProf Blog Weekend Roundup

Sunday, August 9, 2015

Capitalists, Arise: We Need To Deal With Income Inequality

OccupyNew York Times Sunday Review:  Capitalists, Arise: We Need to Deal With Income Inequality, by Peter Georgescu (Chairman Emeritus, Young & Rubicam):

I’m scared. The billionaire hedge funder Paul Tudor Jones is scared [video below]. My friend Ken Langone, a founder of the Home Depot, is scared [video below]. So are many other chief executives. Not of Al Qaeda, or the vicious Islamic State or some other evolving radical group from the Middle East, Africa or Asia. We are afraid where income inequality will lead.

For the top 20 percent of Americans, life is pretty good.

But 40 percent are broke. Every year they spend more than they have. ...

If inequality is not addressed, the income gap will most likely be resolved in one of two ways: by major social unrest or through oppressive taxes, such as the 80 percent tax rate on income over $500,000 suggested by Thomas Piketty, the French economist and author of the best-selling book “Capital in the Twenty-First Century.”

We are creating a caste system from which it’s almost impossible to escape, except for the few with exceptional brains, athletic skills or luck. That’s why I’m scared. We risk losing the capitalist engine that brought us great economic success and our way of life. ...

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August 9, 2015 in Tax | Permalink | Comments (1)

Tax-Exempt Status And Religious (And Other) Organizations After Obergefell

White House Same Sex MarriagePrawfsBlawg:  Garnett et al. on Tax-Exempt Status and Religious (and Other) Organizations, by Paul Horwitz (Alabama):

Should government insist that all private organizations comply with its own sense of the good? Most people, I think, still agree that the answer to this question is no. However strongly they feel that those public values are the right values, and however devoutly they may hope that all people and all groups come to share them and to act accordingly, they still believe for various reasons--not least a sense that the public-private distinction, however imperfect and vulnerable to critique, represents an important value of its own--that government should not and perhaps cannot rigorously or ruthlessly enforce what Nancy Rosenblum has called a "logic of congruence" between public and private organizations. ...

Our friend and fellow Prawfs writer Rick Garnett discusses that question in a new editorial co-written with John Inazu and Michael McConnell. The title, which I gather its writers did not choose and might not be completely comfortable with, is "How to Protect Endangered Religious Groups You Admire." They argue, in brief, that we should, at a minimum, be willing to protect religious non-profits that provide significant contributions to the public good despite their now heterodox views.

Read the whole thing. Feel free to disagree. I will add two points. I agree, in sensibility at least, with a point made by Marc DeGirolami in a recent post about the editorial: "We use the language of 'exemption' when we speak of the taxable status of nonprofits, but it would be better instead to think of their nontaxable status as marking a boundary of the government's power to tax." Reasonable disagreement is available about whether "power" is an apt word here, but for those who believe that whatever the extent of state power, it ought not lightly be exercised in a way that circumscribes civil society and a vibrant pluralism, the sensibility is right. Second, it ought not be only pluralists, and certainly not only social conservatives, who support these arguments. This is an argument that liberals ought to be taking seriously now, especially as progressive thought continues to drift in a more illiberal direction.

Christianity Today op-ed:  How to Protect Endangered Religious Groups You Admire, by  Richard W. Garnett (Notre Dame), John D. Inazu (Washington University) & Michael W. McConnell (Stanford):

Today, tens of thousands of religious organizations, and tens of millions of Americans, continue to believe and teach that the proper understanding of marriage is a union of one man and one woman. But they do far more than believe and teach this and other views.

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August 9, 2015 in Tax | Permalink | Comments (0)

The Top 5 Tax Paper Downloads

The IRS Scandal, Day 822

IRS Logo 2Forbes:  Judicial Watch Reveals That They Read Tax Blogs At IRS, by Peter J. Reilly:

Overall, this particular document dump seems to support the President’s view that what is scandalous is the confusing nature of the law. There is certainly no evidence of political appointees mucking around in the details of IRS operations.

At the time Joe Kristan thought that the IRS was wrong to raise the issue and that Senators were right to call the Service to account about it. And this is the part of the document dump that I found most interesting.  Paul Caron summarized Joe’s post and that was apparently printed out numerous times at the IRS as there are multiple copies in the document dump. At 4889 in the dump James Hogan writes to Leslie Finlow

I know you’ve been sucked into this particular morass – thought you might find this useful.

The only problem is that Paul Caron is a pretty good looking guy, but if you take the picture then used on TaxProf, print it out, photo copy it and then scan it, he looks a little villainous.

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August 9, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (1)

Saturday, August 8, 2015

This Week's Ten Most Popular TaxProf Blog Posts

NY Times: IRS To Unveil New Rules Curtailing Family Limited Partnerships

FLPNew York Times:  Navigating Tougher I.R.S. Rules for Family Partnerships, by Paul Sullivan:

The Internal Revenue Service is about to toughen the rules on a type of investment vehicle that has been abused by some very wealthy families to avoid millions of dollars in taxes.

The wealthy are allowed to use family limited partnerships, family limited liability companies and their variants to hold family businesses, real estate or other illiquid, hard-to-value investments. And they can discount the value of the assets because that is seen as the only way people outside the family would buy in, particularly since nonfamily members have no control over what the partnership does.

But some partnerships have put marketable securities, even cash, into the entities and still claimed a discount even though the investments have a value that is easy to determine. Others have taken steep and unreasonable discounts on the value of the partnership shares solely on the basis that the entity itself is family-owned.

A few have gone so far as to value the assets they hold at a steep discount for estate tax purposes only to turn around and liquidate the partnerships and distribute the cash as soon as the statute of limitations on estate tax audits has passed.

Stung by its mixed record in challenging these entities in court, the I.R.S. could soon get help from the United States Treasury. Cathy Hughes, an attorney-adviser at the Treasury’s office of tax policy, said in May that new regulations restricting what would be allowed with family partnerships could be released as soon as mid-September.

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August 8, 2015 in IRS News, Tax | Permalink | Comments (1)

Scholastica: Law Review Article Submissions Insights

Scholastica 2Scholastica, Law Review Article Submissions Insights: A Data-Driven Look Into the Yearly Legal Scholarship Cycle:

The Scholastica team read PrawfsBlawg’s “Some Results from the Law Review Submission Practices Survey” post and comments a few months ago, and it stuck in our minds.

Specifically, we thought it was clear that authors want to know: “For a legal scholar, when is the best time to submit a manuscript to a law review?” We realized that, as a portal for hundreds of top law reviews, we could dig into our data (anonymized and aggregated, of course) to see what the yearly life cycle for law reviews looks like and see if we can help answer that question.

Spoiler: we don’t know when the best time to submit a law review article is. Sorry about that! ... We've created a series of interactive charts to offer rich insight into our data.

Scholastica 1

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August 8, 2015 in Legal Education | Permalink | Comments (0)

The IRS Scandal, Day 821

IRS Logo 2Forbes:  Dear IRS Employees: Emails Go To Congress, So Let's Text, by Robert W. Wood:

For more than two years, President Obama has denied there is an IRS problem, quipping that there is not a smidgen of corruption at the IRS. He has long claimed that any missteps were innocent, entirely the fault of bonehead decisions in local offices. ...

Yet it is harder and harder to believe. IRS documents have revealed a Lois Lerner email about teaching IRS staffers to understand the potential pitfalls of revealing too much information to Congress. Forget email. Instead, the IRS used a neat instant messaging system that automatically deleted office communications. House Oversight Committee documentation suggests it was used deliberately by IRS officials to evade public scrutiny. The fact that the IRS use instant messaging to hide internal communications came out more than a year ago, yet it is still pooh poohed by the administration. ...

Some of the real juice may be in text or instant messages. In 2013, when the IRS targeting scandal was brewing, Ms. Lerner asked an IRS IT specialist if the IRS saved texts? The response was music to Ms. Lerner’s ears. No, they are not automatically saved, was IT’s response. The IT person went on to say that saving them was possible, though, so be careful. “Perfect,” was Ms. Lerner’s reply. And remember all those many millions of dollars of taxpayer money the IRS spent looking?

Yet House Members were recently told by the Inspector General that the IT staff of the IRS said they were never even asked for backup tapes to find Lerner’s emails. Deputy Inspector General Tim Camus said finding the emails was easy. “They were right where you would expect them to be,” he told the Oversight Committee. ...

Mr. Koskinen has testified before Congress numerous times. On March 26, 2014, he pledged that the IRS would produce all of Ms. Lerner’s emails. Yet he knew there were big problems, and the ‘facts’ and dates just don’t line up. Mr. Koskinen lamented the lost or destroyed backup tapes. Mr. Koskinen testified he had “confirmed” that all of the tapes were unrecoverable.

In fact, approximately 700 backup tapes had not been erased and contained relevant information. The inspector general said the 700 still-good backup tapes recovered were found within 15 days of the IRS’s informing Congress they were not recoverable! What was so difficult? The inspector general’s staff simply drove to Martinsburg, WV and asked for the tapes. The IRS had never even asked whether the tapes existed. Well, maybe they sent a text.

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August 8, 2015 in IRS News, IRS Scandal, Tax | Permalink | Comments (3)

Friday, August 7, 2015

Carly Fiorina, Republican Debate Winner, Is The Daughter Of The Late 9th Circuit Judge (And Tax Prof) Joseph Sneed

CarlyCarly Fiorina, the consensus winner of last night's Republican presidential debate, is the daughter of the late Ninth Circuit Judge Joseph Sneed, who was a Tax Prof at Texas (1947-57), Cornell (1957-62), and Stanford (1962-71), as well as Dean of Duke Law School (1971-73). He was the author of two opinions that are staples in most income tax casebooks:

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August 7, 2015 in Legal Education, Tax | Permalink | Comments (0)

Weekly Tax Roundup