Office of the Law School Registrar
Course Directory

Graduate Tax Directory
Fall 2000


ADVANCED INCOME TAXATION
William A. Drennan
Robert F. Dwornick
W77-727B sec 01 (3 hrs)
WED, FRI 8:00 - 9:30 a.m.

The segment involves various tax accounting principles and concepts including; (i) the selection of taxable year (i.e., the period for the computation of taxable income of a taxpayer); (ii) the timing of income and deductions (including net operating loss deductions, net operating loss carrybacks and carryovers, the tax benefit rule, the claim of right doctrine); (iii) methods of accounting for income and deduction (i.e., the cash method and accrual method); (iv) transactions between related taxpayers; and (v) the mitigation of the statute of limitations for assessment of tax and claiming tax refunds, i.e., the rules for correcting errors made in years with respect to which the statute of limitations for assessment of tax for claiming a tax refund have expired. The course also analyzes the income tax consequences of sales and exchanges, gifts, and bequests, including (i) the calculation of gain or loss; (ii) the tax basis of the property acquired, (iii) the availability of long-term capital gain tax rates on a sale; (iv) the restrictions on the deductibility of capital losses; and (v) nonrecognition transactions.

FEDERAL INCOME TAX
Peter Wiedenbeck
W74-549G sec 01 (4 hrs)
MON, TUE, THU 8:50 - 10:00 a.m.

This course is a survey of the federal income taxation of individuals, with consideration of the nature of income, when and to whom income is taxable, exclusions from the tax base, deductions, credits and the tax consequences of property ownership and disposition. The instructor emphasizes tax policy and statutory interpretation. The course will be taught from a casebook and a statutory pamphlet, by a combination of the case and problem methods. Students will work extensively with the Internal Revenue Code. Attendance and preparation are required and sanctions will be imposed on serious offenders. The course grade will be based predominately on a timed final examination.

FEDERAL PARTNERSHIP TAXATION
Phillip B. Wright
Thomas A. Boman
W77-725C sec 01 (3 hrs)
SAT 9:00 - 11:00 a.m. + WED 8:00 - 9:00 a.m.

The course will survey Subchapter K of the Internal Revenue Code, which deals with the federal income taxation of partnerships and other pass-through entities. Subjects to be covered will include classification of entities as partnerships; tax consequences of capital contributions, partnership liabilities, and liquidating and non-liquidating distributions; allocations of profits and losses; basis of partnership interests; impact of shifts in partnership interests; and planning for family partnerships.

FEDERAL TAX PROCEDURE
Robert J. Burbank
Harry Charles
Donald Wells
W77-704B sec 01 (3 hrs)
MON 4:30 - 7:30 p.m.

This course will examine the administrative and judicial procedures for resolving federal tax disputes. Covered topics will include: Organization of the Internal Revenue Service, legal and ethical responsibilities of tax practitioners, administrative appeals procedures, Tax Court litigation, civil and criminal penalties, statutes of limitation, and collection procedures.

INTRODUCTION TO U.S. TAXATION
OF FOREIGN INCOME

Carl A. DiLisio
W77-712A sec 01 (3 hrs)
MON, FRI 8:00 - 9:30 a.m.

The course examines jurisdiction to tax, source of income, allocation of expenses, foreign tax credit mechanism, foreign tax credit limitation, transactions between related companies, tax favored transactions, organization/reorganization of entities involved in foreign jurisdictions and other related topics.

PASS THROUGH BUSINESS TAXATION:
PARTNERSHIPS AND LIMITED LIABILITY COMPANIES

Peter Wiedenbeck
W74-581E sec 01 (3 hrs)
MON, TUE, THU 12:00 - 1:00 p.m.

This course involves an intensive study of the federal tax treatment of partnerships and limited liability companies. The income of these enterprises is taxed directly to the business owners as it is earned, whether or not it is distributed. Topics covered will include the tax consequences of business organization, profit and loss allocations among owners, transactions between owners and the firm, sales of ownership interests, distributions to owners, and partial and complete liquidations of ownership interests. The pass-through tax regime will be compared with the tax treatment of sole proprietorships, regular and small business corporations (i.e., C and S corporations), and important issues in business tax policy will be explored. Students will work extensively with Subchapter K of the Internal Revenue Code and the regulations thereunder. The course will be taught from a casebook and a statutory pamphlet, by a combination of case and problem methods. Federal Income Taxation is not a prerequisite for this course, but it is highly desirable to take Federal Income Tax before taking this course. Attendance and preparation are required and sanctions will be imposed on serious offenders. The course grade will be based predominately on a final examination, which may be a take-home exam.

STATE AND LOCAL TAXATION

Harlan J. Kwiatek
Brenda L. Talent
Raymond T. Wagner
W77-711B 01 (3 hrs)
TUE, THU 4:30 - 6:00 p.m.

This is a course which provides an in-depth overview of the state and local taxation of businesses and individuals. Topics include state corporation income taxes, franchise taxes, state sales and use taxes, real and personal property taxes, and state and local personal income taxes. The course also includes a survey of common state and local tax procedures and state and local tax related constitutional issues.

TAX PLANNING FOR REAL ESTATE INVESTMENTS AND CLOSELY HELD BUSINESSES: SELECT ISSUES
Thomas A. Duda
Michael A. Markenson
Jay A. Nathanson
W77-723B 01 (3 hrs)
TUE 8:00 - 10:30 a.m.

The course will address: choice of entity; sale and exchange considerations for real estate investments and closely held businesses, including mergers and acquisitions, like kind exchanges, and installment sales; passive loss rules; cancellation of debt; and tax credit and other issues that arise in connection with the development of historic and non-historic structures, low income housing, and other real estate transactions.