1515 Commerce St.
Fort Worth, TX Tarrant County 76102
United States
Texas A&M University School of Law
Federal Election Campaign Act, campaign contributions, conduits, Buckley, Valeo, criminal prosecution, mens rea, preemption, greater included offense, First Amendment, political speech and association
IRS, tax, interest, netting, abatement
TEFRA, partnership, Internal Revenue Service, IRS, multi-tiered structure, pass-through partner, indirect partner, source partnership, notice partner, notification, right to participate, statute of limitations. settlements, direct partner, FPAA, tax matters partner, TMP
Internal Revenue Service, IRS, uncertain tax positions, UTP, FIN 48, privilege, waiver, work-product doctrine, tax accrual workpapers
Internal Revenue Service, IRS, audit, examination, appeals, rules, procedures
Tax Court, Internal Revenue Service, IRS, Barclays, BNY Mellon, structured trust advantaged repackaged securities transaction, STARS transaction, foreign tax credit, FTC, economic substance
Santa Clara Pueblo v. Martinez, civil rights, federal jurisdiction, subordinate sovereign governments, deterrence
Internal Revenue Service, IRS, Circular 230, tax return preparers, practitioners, regulation, practice before the IRS, Loving
income tax, IRS, interest, computation
TEFRA, partnership, tax, IRS, refund, AAR, FPAA, statute of limitations, TMP, mitigation, equitable recoupment, discretionary adjustment
tax, Internal Revenue Service, reportable transactions, listed transactions, American Jobs Creation Act, disclosure, list maintenance, penalties
