Volume 11 (2013) ISSN (print) (online) DOI /taxreview

Similar documents
Volume 12 (2014) ISSN (print) (online) DOI /taxreview

INFORMATION FOR AUTHORS

Information for Authors and Editors

TIPS FOR FORM & ACCURACY RESEARCH: STARTING POINTS FOR JOURNAL FORM & ACCURACY ASSIGNMENTS

Access Infrastructure

2018 Howard County 4-H Livestock Sale Processing - All

80% reported print versions of texts/treatises are very important or extremely important

Understanding and Mastering The Bluebook

How to Choose the Right Journal? Navigating today s Scientific Publishing Environment

repercussions ~ ercusstons founding editors managing editor editors editorial board advisory board design 6- typesetting

The Honor Code: Plagiarism and Journals CHARTERED 1693

TULANE ENVIRONMENTAL LAW JOURNAL

MARIAH MAGAZINE HOTTER N HELL! LADIES! ENTER NOW THE MODEL SUBMISSION PERIOD FOR HOMETOWN HOTTIES IS NOW OPEN SUBMIT PHOTOS TO

New Formalist Criticism

Journal of Academy of Juridical Studies

Nursery Rhymes and Fables

Journal of Japan Academy of Midwifery Instructions for Authors submitting English manuscripts

You Want Me To Research WHAT?! (Getting Background & Keeping Current) Jennifer Behrens April 7, 2008

JOURNAL OF INTELLECTUAL PROPERTY AND ENTERTAINMENT LAW

Legal Research Refresher: Secondary Authority Guide

Advisory and Editorial Boards

Choral Composition Contest

The Trademark Reporter Submission Guidelines (7.7.17)

CAMBRIDGE YEARBOOK OF EUROPEAN LEGAL STUDIES NOTES FOR CONTRIBUTORS

Legal Periodical Indexes

Archiving Your Research: the UNM Institutional Repository

Law Library. Hofstra. Supporting the Curricular and Research Needs of the Students and Faculty of Hofstra Law. FACULTY EDITION

Understanding and Mastering The Bluebook

Instructions to Authors

Frequently Asked Questions about Rice University Open-Access Mandate

PERSPECTIVES. Teaching Legal Research and Writing UNIFORM CITATION GUIDE INTRODUCING THE AALL CONTENTS

Thank you for purchasing an Evan-Moor e-book!

ND Law Library Guide

TESOL-SPAIN NEWSLETTER (ISSN ) SUBMISSION GUIDELINES

Journal of Equipment Lease Financing Author Guidelines

Submission Guidelines for HPNLU Law Review (HPNLULR)

Harvard Law School Library Collection Development Policy

Warriors Magazine, LLC

Negotiation Exercises for Journal Article Publishing Contracts and Scholarly Monograph Publishing Contracts

Lippincott Williams & Wilkins, Inc. Health Care Management Review Author Guide

Self-Publication on the Internet and the Future of Law Reviews. Gregory E. Maggs*

Feminine Subjects in Masculine Fiction

Advertisements, Title Page, Copyright Page, Contents

LIBRARY. Children s Access and Use of Digital Resources. Allison Druin, Issue Editor. Published by The Johns Hopkins University Press

Instructions to Authors

Publishing India Group

SUBMISSION GUIDELINES Contingent Horizons: The York University Student Journal of Anthropology

Faculty Newsletter (August 2012)

OPARCH (opinion) Journal of Architectural Education Manuscript Guidelines and Submission Protocols

Mission Studies brill.com/mist. Scope. Ethical and Legal Conditions. Online Submission. Instructions for Authors

REGULATION EDITION. August 30 th September 8 th, 2019

INSTRUCTIONS FOR AUTHORS (i)introduction

Broadcasting Decision CRTC

KATHERINE M. RAMSLAND PAPERS Mss (Acc , , , , , , ) Container List

How-To Guide. Lexis for Microsoft Office

The Reference Department of the Lorette Wilmot Library at Nazareth College

Charlotte Brontë: The Novels

Instructions to Authors

International Community Law Review. Scope. Ethical and Legal Conditions. Instructions for Authors

Electronic Literature

BRITAIN AND THE MAASTRICHT NEGOTIATIONS

Author Frequently Asked Questions

Thesis Format Guide. Page 1 of 12 1/2018

Canadian Journal of Neurological Sciences Instructions for Contributors

EX NOVO Issue n. 2. Who Owns the Past? Archaeological Heritage between Idealization and Destruction

Primary Source Documents

DOI: / Open-Air Shakespeare

Hysteria, Trauma and Melancholia

Perspectives in Education

Barb Campbell 3/24/17-10:30am-1:00pm - PH360

Finding Aid for the Matt Weinstock Papers, No online items

SUPPORT FOR PUBLISHERS

The Jon Vickers Film Scoring Award 2017/2019 Entry Form and Agreement

ADVANCED TELEVISION SYSTEMS COMMITTEE, INC. CERTIFICATION MARK POLICY

Knowledge Quest Author Guidelines

Terms of Use and The Festival Rules

Theatre and Residual Culture

THE LONG PROCESS OF DEVELOPMENT

Human Rights Violation in Turkey

FCC 396. BROADCAST EQUAL EMPLOYMENT OPPORTUNITY PROGRAM REPORT (To be filed with broadcast license renewal application)

TESOL-SPAIN NEWSLETTER SUBMISSION GUIDELINES

By Lawrence F. Lowery. Copyright 2013 NSTA. All rights reserved. For more information, go to

Questions about these materials may be directed to the Obstetrics & Gynecology editorial office:

ANALYSING TEXTS General Editor: Nicholas Marsh Published

presents TEACH US TO Download now at songdiscovery.com Expires 2/29/16. Valid for subscribers JAN/FEB 2016 Volume 126

How to be an effective reviewer

HENRY FIELDING. Literary Lives General Editor: Richard Dutton, Professor of English Lancaster University

INSTRUCTIONS TO THE AUTHORS FOR PUBLICATION IN BJ KINES-NATIONAL JOURNAL OF BASIC & APPLIED SCIENCE

King's College STUDY GUIDE # 4 D. Leonard Corgan Library Wilkes-Barre, PA 18711

William H. Emerson Family Papers

Class B digital device part 15 of the FCC rules

GPLL234 - Choosing the right journal for your research: predatory publishers & open access. March 29, 2017

OPERATION MANUAL. FA-9600 LUT-Converter. Version Higher

Communications Commission Washington, D.C ) ) ) ) ) ) ) The American Cable Association ( ACA ) hereby submits these comments in

Volume 1.1 (2011): ISSN (print) (online) DOI /cinej

BY KIRSTEN K. DAVIS & TAMARA HERRERA

Prefatory Page (no page #) Committee Member Page (for Project or Thesis)

The CYCU Chang Ching Yu Memorial Library Resource Development Policy

West End Baptist Church - Senior Piano - Adjudicator: Andree Azar

Author Submission Packet for HAPS-EDucator

Transcription:

Volume 11 (2013) ISSN 1932-1821 (print) 1932-1996 (online) This work is licensed under a Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 United States License. This journal is published by the University Library System of the University of Pittsburgh as part of its D-Scribe Digital Publishing Program, and is cosponsored by the University of Pittsburgh Press.

PITTSBURGH TAX REVIEW Volume 11 Fall 2013 Issue 1 TABLE OF CONTENTS ARTICLES AUER/SEMINOLE ROCK DEFERENCE IN THE TAX COURT Steve R. Johnson... 1 LET S GET TOGETHER : COLLABORATIVE TAX REGULATION Danshera Cords... 47 THOSE WHO KNOW, THOSE WHO DON T, AND THOSE WHO KNOW BETTER: BALANCING COMPLEXITY, SOPHISTICATION, AND ACCURACY ON TAX RETURNS Michelle Lyon Drumbl... 113 i

PITTSBURGH TAX REVIEW Volume 11 Fall 2013 Issue 1 James Flannery Faculty Editor 2013 2014 EDITORIAL BOARD Senior Editors Mirit Eyal-Cohen Chief Faculty Anthony C. Infanti Faculty Editor Jane He Executive Editor Kristopher E. Micknowski Articles Editor Sung Un Kim Michael J. Pisarcik Bluebook Editors Elina Aleynikova Anya Bogusky Liz Cook Julie Ann Deisher Blair Douglass Janai Gall Katherine Getty Emily Grawe Edward Thomas Hirsh Alexa Hunter Saheli Chakrabarty Editor-in-Chief Managing Editors Becky Armady Travis G. Maurer Emily Osgood Megan R. Sasinoski Associate Editors Jeb Keller Frank Kimmel Kaylee Klixbull Brigette R. Koreny Christopher Manzi Cristian Minor Addison Morris Jane Myhers Ben Ochs Thea Paolini Jennifer L. Powell University of Pittsburgh School of Law Barco Law Building 3900 Forbes Avenue Pittsburgh, PA 15260 http://taxreview.law.pitt.edu taxrev@pitt.edu Sarah Knerr Production Editor Max Slater Notes Editor Katelyn M. Dornburg Research Editor Victoria Powell Jack Ryan Mary K. Sisca Peter L. Snyder Sarah Steers Leslie Stewart-Hood Claire Throckmorton Jeffery Tisak Jingjing Xia Kyle M. Yeversky ii

General Publication Information The Pittsburgh Tax Review is published biannually by the University Library System, University of Pittsburgh. Subscriptions: $45.00 per volume for U.S. delivery and $60.00 per volume for foreign delivery. Subscriptions are automatically renewed if notice of termination is not received before the expiration of the current subscription period. The Pittsburgh Tax Review is available online through WESTLAW and LEXIS /NEXIS and at http://taxreview.law.pitt.edu. Complete volumes and single issues are available exclusively from the William S. Hein & Co. Inc.; they can be obtained by mail by writing to William S. Hein & Co. Inc., 1285 Main Street, Buffalo, NY 14209; by calling William S. Hein & Co. Inc. at 1-800- 828-7571; or in electronic format on HeinOnline (http://heinonline.org). Copyright for each work contained in this issue is retained by the author and under a Creative Commons Attribution-Noncommercial-No Derivative Works 3.0 United States License. Except as otherwise expressly provided, the Pittsburgh Tax Review hereby grants permission for copies of articles to be made for classroom use in nationally accredited law schools, provided (1) copies are distributed at or below cost, (2) author and journal are identified, and (3) proper notice of copyright is affixed to each copy. Views expressed in the articles, editorial comment, book reviews, notes, and other contributions appearing in the Pittsburgh Tax Review are those of the individual authors and do not necessarily represent the views of the Editorial Board or the University of Pittsburgh School of Law. Citation References All references and citations to sections in this issue are to sections of the Internal Revenue Code of 1986 ( The Code ), as amended, unless otherwise indicated. All references and citations to regulations are to Treasury Regulations under the Internal Revenue Code of 1986, as amended, unless otherwise indicated. iii

Manuscript Submissions The Pittsburgh Tax Review invites submissions of unsolicited manuscripts from faculty, judges, and practitioners. The Pittsburgh Tax Review requests that manuscripts be accompanied by an abstract of not more than 200 words describing the contents of the article. The submissions will be reviewed and decided upon by the Faculty Editors. All citations should conform to The Bluebook: A Uniform System of Citation (19th ed. 2010). Submissions should be sent to: Editor-in-Chief, Pittsburgh Tax Review, University of Pittsburgh School of Law, Barco Law Building, 3900 Forbes Avenue, Pittsburgh, Pennsylvania, 15260. Electronic submissions are accepted and can be sent to taxrev@pitt.edu. Electronic submissions are also accepted through ExpressO online submission delivery service. Manuscripts cannot be returned. iv