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Publications: Tax Accounting

Reclassifying Section 174 Costs - Amended Returns versus Form 3115
IP&B Tax Insider, February 6, 2017
Standing Issues in Direct APA Challenges to Tax Regulations
Tax Notes, November 23, 2015
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
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
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
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
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
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
The APA's Arbitrary and Capricious Standard and IRS Regulations
Tax Notes, July 16, 2012
What We Didn’t Learn From Home Concrete
Tax Notes, June 25, 2012
Standards for Tax Court Review in Equitable Innocent Spouse Cases
Tax Notes, February 20, 2012
Is the Anti-Injunction Act Jurisdictional?
Tax Notes, November 28, 2011
Schedule UTP: Ready or Not, Here It Comes
Tax Management Real Estate Journal, September 1, 2010
Omissions From Gross Income And the Chenery Rule
Tax Notes, August 16, 2010
Brand X and Omissions From Gross Income
Tax Notes, February 1, 2010
Tax Savings Idea - Change in Treatment of Exchanges of Intangibles For Exchanges that Have Already Taken Place and Been Reported as Taxable
Ivins, Phillips & Barker, November 30, 2009
Maximizing the Benefits of Sec. 199 in an Asset Sale
The Tax Advisor, May 1, 2008
Leading Lawyers
The Legal Times, July 18, 2005
Final UNICAP Regulations Expand Some Exceptions but Eliminate Others
Journal of Taxation, January 1, 1994
Final Regs. On Economic Performance Requirement Resolve Most Issues
Journal of Taxation, July 1, 1992
When will Interest be Capitalized Under the New Proposed Regulations?
Journal of Taxation, January 1, 1991
Long-Term Contract Regulations: Endless Complexity and Planning Opportunities
Journal of Taxation, January 1, 1986
Premature Accruals and the Relationship Between Accounting Methods and the Penalty Provisions
Univ. of Southern California Law Center, Thirty-Seventh Tax Institute, January 1, 1985

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