Professional Publications

Professional Publications

New York's Transparency Law Lacks the Teeth of Its US Twin, Bloomberg Tax (Nov. 7, 2023). 

Representing Clients With Foreign Bank Accounts, 2023 NYU Tax Controversy Forum (June 9, 2023) (moderator) 

Congressional Subpoenas to Accountants, The CPA Journal (July 2019).  Please click here to view the .pdf.

Avoiding the Worst Case Scenario: The IRS's Domestic Voluntary Disclosure Practice, The CPA Journal (June 2016).  Please click here to view the .pdf.

Waiving the Fifth Amendment Before Congress – Not As Easy As Congress Might Hope, The Champion (NACDL), Vol. XXXVII, No. 7 (Aug. 2013)  (Nb: Congress dropped its Fifth Amendment position shortly after publication).  Please click here to view the .pdf.

Can IRS Be Trusted? A Troubling New Development In The Offshore Voluntary Disclosure Program, 118 Journal of Taxation 182 (Apr. 2013) (Nb: IRS reversed its position shortly after publication).  Please click here to view the .pdf.

Tax Controversies: Audits, Investigations, Trials, 2 vols. (Matthew Bender, 1980, 28th-37th Revs., 2011-2019),  Chapter 21, Sentencing (contributing author, 2011-2019).

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