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Richard J. Kovach
• Taxation of Below-Market Loans Under § 7872:* This Could be a Lot Simpler! *I.R.C. 7872 (2000)
John A. Lynch, Jr.
• Attaining U.S. Effectively Connected Income in the Aftermath of the American Jobs Creation Act of 2004 and Its Aim to Repeal Extraterritorial Income Exclusion
• Bright Line, Dim Prospects: Grupo Dataflux v. Atlas Global Group, L.P. Reaffirms a Bright Line Barrier to Diversity Jurisdiction for Limited Partnerships and Other Unincorporated Entities