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Publications: Tax Controversies

Guide to Civil and Criminal Tax Penalties
Lexis Practice Advisor, August 19, 2018
Tax Court Litigation Basics
August 19, 2018
"The Problem With Wearing Two Hats"
Tax Notes, November 6, 2017
Why "Rite Aid" Was Right
Tax Notes, April 17, 2017
Ivins Attorney Doug Andre Quoted Regarding Expatriation
BloombergBNA Daily Tax Report, February 9, 2017
"How the Election May Affect the Taxation of Business Income"
journalofaccountancy.com, January 27, 2017
Final Regulations Issued for Foreign-Owned Disregarded Entities
Corporate Tax Insider, December 22, 2016
Marvel and United Dominion's Dangerous Dictum
TaxNotes, October 10, 2016
"Defending Transfer Pricing Audits Under the IRS's New Roadmap"
Tax Notes, April 28, 2014
Standing Issues in Direct APA Challenges to Tax Regulations
Tax Notes, November 23, 2015
"Coming Conflicts: Proposed U.S. Transfer Pricing Services Regulations and the Treatment of Intangibles"
6 Derivatives and Financial Instruments No. 5, September 30, 2004
Patrick Smith Recently on List of Top Ten Downloads for U.S. Administrative Law e-Journal
August 21, 2015
Pat Smith's Two-Part Blog on Florida Bankers Association v. Treasury Department Featured in Procedurally Taxing
Procedurally Taxing, August 18, 2015
Ivins Attorney Pat Smith's Recent Blog Post on Altera Decision
Yale Journal on Regulation, August 6, 2015
Pat Smith Featured in Top 10 Most Downloaded Administrative Law Articles
Administrative Law SSRN Reading List /June 2015 Edition, July 14, 2015
Patrick Smith Posts at TaxProf Blog on D.C. Circuit Z Street opinion and is quoted by Bloomberg BNA Daily Tax Report on the same subject
June 23, 2015
Summary Posted TaxProf Blog of Patrick Smith's Recent Tax Notes Article
TaxProf Blog, June 10, 2015
Ivins Attorney, Patrick Smith, Guest Blogger re: Supreme Court's Direct Marketing Decision
Procedurally Taxing, June 8, 2015
Challenges to Tax Regulations: The APA and the Anti-Injunction Act
Tax Notes, May 25, 2015
IRS Issues Guidance Regarding Credits and Refunds of Tax Withheld from International Payments
Employee Benefits Insider & Corporate Tax Insider, April 29, 2015
Patrick Smith, A Thank You for Being One of the "Finest Guest Posters"
Procedurally Taxing, April 6, 2015
Ivins Attorney, Patrick Smith, Guest Blogger re: Perez v. Mortgage Bankers Association
Procedurally Taxing - Legal Tax Blog, March 10, 2015
Ivins Attorney, Patrick Smith, Guest Blogger, re: Supreme Court's Direct Marketing Case
Procedurally Taxing - Legal Tax Blog, March 4, 2015
Contingent Purchase Price, Contingent Liabilities and Indemnities in Taxable Acquisitions
Ivins, Phillips & Barker, November 6, 2014
Ivins Attorneys Quoted in Tax Notes Today on Inversion Guidance
Tax Notes Today, September 24, 2014
Interest Netting Between Merging Corporations
Corporate Tax Insider, July 8, 2014
The End of Circular 230 Disclaimers
Employee Benefits Insider, June 11, 2014
Brand X, 3M, and Legal Restrictions On the Payment of Income
Tax Notes, March 24, 2014
District Court Misapplies APA in Florida Bankers Association
Tax Notes, February 17, 2014
BEPS Update: Country-by-Country Reporting
Corporate Tax Insider, February 5, 2014
IPB Attorneys Comment on OECD BEPS-Related Initiative
February 1, 2014
There's a war over R&D tax credits, and companies keep winning. (quoted in blog by Jia Lynn Vang)
Washington Post.com, January 24, 2014
Prototypes and Depreciable Property: An Attempted Distinction
Tax Notes, January 20, 2014
May Regulations That Violate the APA Be Remanded to the IRS?
Tax Notes, October 7, 2013
Quality Stores and the Status of Revenue Rulings
Tax Notes, September 9, 2013
Note, Incentivizing Conservation: Restructuring the Tax-Preferred Easement Acceptance Process to Maximize Overall Conservation Value
101 Geo. L.J. 1587, August 4, 2013
Chevron's Conflict with the Administrative Procedure Act
Virginia Tax Review, June 25, 2013
PPL: How to Determine Whether a Foreign Tax Is Creditable
Tax Notes, March 18, 2013
U.S. IRS, Lockheed fight over R&D 'rocket science' tax break (quoted in article by Patrick Temple-West)
Business News, January 25, 2013
Application of Proposed CERT Regulations to Acquisitions by Controlled Groups
BNA Tax Management Memorandum, October 22, 2012
The APA's Arbitrary and Capricious Standard and IRS Regulations
Tax Notes, July 16, 2012
Waiting for Direction on Refund Penalties (quoted in article by J. Coder)
July 2, 2012
What We Didn’t Learn From Home Concrete
Tax Notes, June 25, 2012
Appeals Restrictions in Cornyn Legislation Get Mixed Reaction
Tax Analysts, April 27, 2012
Requests for Admission in Federal Tax Litigation: Uses, Limitations, Rules, and Strategic Considerations
Journal of Tax Practice & Procedure, February-March 2012
Standards for Tax Court Review in Equitable Innocent Spouse Cases
Tax Notes, February 20, 2012
Expedited Opt-Out Needed for OVDI Participants Who Owe No Tax
Tax Notes, January 30, 2012
The APA’s Reasoned-Explanation Rule and IRS Deficiency Notices
Tax Notes, January 16, 2012
Overcoming Appeals' Bad Rap (quoted in article by J. Coder)
Tax Notes, September 26, 2011
DC Circuit: 'The IRS Is Not Special'
Tax Notes, August 30, 2011
Nature Abhors a Splitter: The FTC Splitter and Indirect FTC Rules
Tax Notes, February 14, 2011
Mayo and Chenery: Too Much of a Shift in Rationale?
Tax Notes, October 25, 2010
Gaps in the Seventh Circuit's Reasoning in Lantz
Tax Notes, September 27, 2010
Schedule UTP: Ready or Not, Here It Comes
Tax Management Real Estate Journal, September 1, 2010
Recovery of Madoff-Related Tax Losses
Ivins, Phillips & Barker, December 22, 2008
Leading Lawyers
The Legal Times, July 18, 2005
Financing Foreign Operations Through Domestic Finance Subsidiaries
Virginia Law Review, 1969

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