Publications

Books

• Understanding Corporate Taxation (Carolina Academic Press)
  • 5th edition in progress (with Emily Cauble) 
  • 4th edition, 2020 (with Michelle M. Kwon) (updated through the CARES Act)
  • 3rd edition, 2016 (with Michelle M. Kwon)
  • 2nd edition, 2006
  • 1st edition, 2002
• Tax Controversies: Practice and Procedure (Carolina Academic Press) (all editions and updates with Stephen W. Mazza)
  • 4th edition of Casebook, 2018 & Teacher's Manual
    • 2022 Cumulative Supplement (updated through the Inflation Reduction Act)
    • Previous updates: 2020 & 2021 cumulative Supplements; 2018 & 2019 cumulative Letter Updates
  • 3rd edition of Casebook & Teacher's Manual (LexisNexis), 2009
    • Updates (cumulative Supplement or Letter Update): annually, 2010-2016
  • 2nd edition of Casebook & Teacher's Manual, 2002
    • Updates (cumulative Supplement or Letter Update): annually, 2004-2007
  • 1st edition of Casebook & Teacher's Manual, 2000
    • Supplement, 2001
• Tax Controversies: Statutes, Regulations and Other Materials (LexisNexis) (with Stephen W. Mazza)
  • Editions: 1st (2000); 2nd (2002); 3rd (2006); 2013 edition
• Federal Tax Practice and Procedure (LexisNexis, 2003) (General Editor and contributing author/editor)

Articles

Working Papers

• "The Untold Tale of A Tax Rulings Haven" (submitted Aug. 2023)
• "Is the Taxpayer Bill of Rights Enforceable?" (SSRN Working Paper, 2019)

Law Review Articles

• "Avoiding Scandals Through Tax Rulings Transparency," 50 Fla. State L. Rev. 219 (2023)
  • Favorably reviewed by Blaine Saito on TaxProf blog.
• "Valuation As a Challenge For Tax Administration," 96 Notre Dame L. Rev. 1495 (2021) (symposium essay)
• "The Fraud Triangle and Tax Evasion," 106 Iowa L. Rev. 1153 (2021).
  
  • Winner (along with 2 others) of the 2021 Southeastern Association of Law Schools "Call For Papers"  competition
  • Summarized in an invited post on Austaxpolicy blog in Australia (July 20, 2021)
  • Featured on Business Scholarship Podcast: "Leandra Lederman on the Fraud Triangle and Tax Evasion" (July 1, 2021)
• "Information Matters in Tax Enforcement," 2020 B.Y.U. L. Rev. 145 (with Joseph C. Dugan).
• "Does Enforcement Reduce Voluntary Tax Compliance?" 2018 B.Y.U. L. Rev. 623. 
  • Favorably reviewed by Orly Mazur on TaxProf blog.
• "IRS Reform: Politics As Usual?," 7 Columbia Tax J. 36 (2016) (symposium).
• Essay, "Restructuring the U.S. Tax Court: A Reply to Stephanie Hoffer & Christopher Walker’s The Death of Tax Court Exceptionalism," 99 Minn. L. Rev. Headnotes 1 (2014).
• "(Un)Appealing Deference to the Tax Court," 63 Duke L.J. 1835 (2014) (symposium).
• "Enforcement as Substance in Tax Compliance," 70 Wash. & Lee L. Rev. 1679 (2013) (with Ted Sichelman).
• "The Use of Voluntary Disclosure Initiatives in the Battle Against Offshore Tax Evasion," 57 Villanova L. Rev. 499 (2012) (symposium).
• "The Fight Over 'Fighting Regs' and Judicial Deference in Tax Litigation," 92 B.U. L. Rev. 643 (2012).
• "A Tisket, A Tasket: Basketing and Corporate Tax Shelters," 88 Wash. U. L. Rev. 557 (2011).
• "W(h)ither Economic Substance?," 95 Iowa L. Rev. 389 (2010).
• Essay, "Reducing Information Gaps to Reduce the Tax Gap: When Is Information Reporting Warranted?," 78 Fordham L. Rev. 1733 (2010).
• "Tax Appeal: A Proposal to Make the U.S. Tax Court More Judicial," 85 Wash. U. L. Rev. 1195 (2008).
• "Statutory Speed Bumps: The Roles Third Parties Play in Tax Compliance," 60 Stanford L. Rev. 695 (2007).
• "‘Stranger Than Fiction’: Taxing Virtual Worlds," 82 N.Y.U. L. Rev. 1620 (2007).
• "Do Attorneys Do Their Clients Justice? An Empirical Study of Tax Court Litigation," 41 Wake Forest L. Rev. 1235 (2006) (with Warren B. Hrung).
• Book review, "Addressing Imperfections in the Tax System: Procedural or Substantive Reform?," 103 Michigan L. Rev. 1432 (2005) (with Stephen W. Mazza).
  Reprinted in condensed form in The Monthly Digest of Tax Articles (Mar. 2006).
• "The Entrepreneurship Effect: An Accidental Externality in the Federal Income Tax," 65 Ohio State L.J. 1401 (2004).
• "Tax Compliance and the Reformed IRS," 51 Kansas L. Rev. 971 (2003) (symposium).
• "The Interplay Between Norms and Enforcement in Tax Compliance," 64 Ohio State L.J. 1453 (2003).
• "Are There Procedural Deficiencies in Tax Fraud Cases?: A Reply To Professor Schoenfeld," 35 Indiana L. Rev. 143 (2001).
• "Equity and the Article I Court: Is the Tax Court's Exercise of Equitable Powers Constitutional?,"5 Fla. Tax Rev. 357 (2001).
  Reprinted by Tax Analysts on line at 2002 TNT 71-44, with a print summary at 95 Tax Notes 443 (2002).
• "Precedent Lost: Why Encourage Settlement, and Why Allow Non-Party Involvement in Settlements?," 75 Notre Dame L. Rev. 221 (1999)
• "Which Cases Go To Trial?: An Empirical Study of Predictors of Failure to Settle," 49 Case W. Res. L. Rev. 315 (1999).
• "'Civil’izing Tax Procedure: Applying General Federal Learning to Statutory Notices ofDeficiency," 30 U.C. Davis L. Rev. 183 (1996).
• "The Excludability of Employment Discrimination Awards Under Code Section 104(a)(2) after Burke v. United States and Commissioner v. Schleier," 28 Ariz. State L.J. 31 (1996).
• "The New Rollover Rules and Twenty Percent Withholding Tax on Pension Distributions: Does Good Pension Policy Favor Their Repeal?," 7 St. Thomas L. Rev. 75 (1994).
• Note, "Viva Zapata!: Toward a Rational System of Forum-Selection Clause Enforcement in Diversity Cases," 66 N.Y.U. L. Rev. 422 (1991).

• Books
• Articles
• Testimony, Reports, and Contributions
• Amicus Briefs
• Back to Top

Other Articles

• "Increasing Transparency in the U.S. Tax Court," Law360 (Dec. 4, 2018)
• "The IRS, Politics, and Income Inequality," 150 Tax Notes 1329 (Mar. 14, 2016).
• "King v. Burwell: What Does It Portend For Chevron's Domain?," 2015 Pepperdine L. Rev. 72 (with Joseph C. Dugan) (symposium).
• "When the Bough Breaks: The U.S. Tax Court’s Branch Difficulties," 34 ABA Tax Section NewsQuarterly 10 (Winter 2015).
• "What Do Courts Have to Do With it? The Judiciary's Role in Making Tax Law," 65 Nat'l Tax J. 899 (2012) (symposium).
• "More Mayo Please? Temporary Regulations after Mayo Foundation v. US," 30 ABA Tax Section NewsQuarterly 15 (2011) (with Stephen W. Mazza).
• "Limitation by Regulation: Heads the Service Wins, Tails the Taxpayer Loses?," 29 ABA Tax Section NewsQuarterly 7 (2010) (with Stephen W. Mazza).
• "EBay’s Second Life: When Should Virtual Earnings Bear Real Taxes?," 118 Yale L.J. Pocket Part 136 (2009) (symposium on virtual worlds).
• "Is a Server Crash Reasonable Cause for Late Filing?," 26 ABA Tax Section NewsQuarterly 12 (2007) (with Stephen W. Mazza).
• "The Federal Income Tax Consequences of the Bobble Supreme Phenomenon,'” 9 Green Bag J. 2d 423 (2006).
• “When Does the Taxpayer Have a Right to an IRS Appeal?,” 25 ABA Tax Section NewsQuarterly 14 (2006) (with Stephen W. Mazza).
• "The New Payment vs. Deposit Landscape," 24 ABA Tax Section NewsQuarterly 7 (2005).
• "Must the Reports of Tax Court Special Trial Judges Be Disclosed?," 2004-2005 S. Ct. Prev. 131 (2004).
• "Delinquent Returns and Credit-Elect Overpayments: A Procedural Tangle," 104 Tax Notes 831 (2004).
• "Does the Burden of Proof Matter?," 23 ABA Tax Section NewsQuarterly 10 (2004).
• "Transparency and Obfuscation in Tax Court Procedure,"102 Tax Notes 1539 (2004).
• "What Has the Fifth Circuit Dunn?," 22 ABA Tax Section NewsQuarterly 9 (2002).
• "Arbitrary Stat Notices or Arbitrary Ninth Circuit?,"92 Tax Notes 231 (2001).
• "Deficient Statutory Notices and the Burdens of Proof: A Reply to Mr. Newton,"92 Tax Notes 117 (2001).
• "Late Returns Claiming Refunds: Negotiating the 'Fantastic Labyrinth'," 89 Tax Notes 1053 (2000).
• "Taxpayer Rights in the Lurch: A Response to Professor Johnson," 88 Tax Notes 1041 (2000).
• "Of Taxpayer Rights, Wrongs, and a Proposed Remedy," 87 Tax Notes 1133 (2000).
• "Unforeseen Consequences of the Burden of Proof Shift," 80 Tax Notes 379 (1998).
• "It’s Time to Fix the ‘Traps for the Unwary’ in the Refund Statutes," 79 Tax Notes 1057 (1998).
• "Tax Court S Cases: Does the 'S' Stand for Secret?," 79 Tax Notes 257 (1998); 18 Tax Prac. 74 (1998).
• "Applying the Refund Statutes to Delinquent Returns," 68 Tax Notes 1639 (1995).
• "The Dilemma of Deficient Deficiency Notices," 73 Taxes 83 (1995).
  • Reprinted by Tax Analysts on line at 95 TNT 46-42 and on microfiche, with a print summary at 67 Tax Notes 1078 (1995).
• "Redemptions Incident to Divorce," 72 Taxes 651 (1994).
  • Reprinted in condensed form in The Monthly Digest of Tax Articles (May 1995).
  • Reprinted as "Redemptions Incident to Divorce: Reconciling Section 1041 and General Tax Principles," 26 U. Toledo L. Rev. 575 (1994).

• Books
• Articles
• Testimony, Reports, and Contributions
• Amicus Briefs
• Back to Top

Testimony, Reports, and Contributions

• Written testimony for the House Ways & Means Committee, Oversight Subcommittee hearing on "Taxpayer Fairness," Oct. 13, 2020 
• Tax Penalties as Instruments of Cooperative Tax Compliance Regimes, Thematic Report for the European Association of Tax Law Professors (Annual Congress Milan 2015), IBFD Amsterdam (2016)
• Surcharges and Penalties in Tax Law: United States, National Report for the European Association of Tax Law Professors (Annual Congress Milan 2015), IBFD Amsterdam (2016) (with Stephen W. Mazza and Steve R. Johnson)
• Entry in Careers in Tax Law (John Gamino, Robb Longman & Matt Sontag, Eds.) (ABA Tax Section, 2009)
• Materials on tax teaching in Teaching the Law School Curriculum (Steve Friedland and Gerry Hess, Eds.) (Carolina Academic Press, 2004)
• Five limericks on tax cases in Barbara Hauser, "Tax Case Limericks: A Casual Collection," 93 Tax Notes 865 (2001).

Amicus Briefs

• Ninth Circuit Brief of Law Academics and Professors as Amici Curiae in Opposition to the Petition for Rehearing En Banc in Altera v. Commissioner (brief filed Sept. 6, 2019) (one of 4 principal coauthors of the brief--Leandra Lederman, Susan Morse, Stephen Shay, and Clint Wallace--and one of 29 academics joining the brief)
• Supplemental Brief of Amici Curiae Reuven Avi-Yonah, Lily Batchelder, Joshua Blank, Noel Cunningham, Victor Fleischer, Ari Glogower, David Kamin, Mitchell Kane, Michael Knoll, Rebecca Kysar, Leandra Lederman, Zachary Liscow, Ruth Mason, Susan Morse, Daniel Shaviro, Stephen Shay, John Steines, David Super, Clinton Wallace, Bret Wells, in Support of Respondent-Appellant Commissioner (brief filed Sept. 28, 2018)
• Brief of Amici Curiae J. Richard Harvey, Leandra Lederman, Ruth Mason, Susan Morse, Stephen Shay & Bret Wells in Altera Corp. v. Commissioner, in Support of Respondent-Appellant Commissioner (brief filed July 1, 2016)
• Brief of Amici Curiae Professor Patricia Cain, et al. in Support of Appellants, in the Ninth Circuit case of Voss v. Commissioner (brief filed Feb. 6, 2013) (One of 11 tax professors joining this brief)
• Brief as Amica Curiae in Ballard v. Commissioner, 544 U.S. 40 (2005) (brief filed Aug. 2, 2004).

• Books
• Articles
• Testimony, Reports, and Contributions
• Amicus Briefs
• Back to Top