Faculty Scholarship

A Primer on Other State Tax Credits, 88 State Tax Notes 1061 (2018).

The Gift of the Tax Guy, 90 State Tax Notes 1143 (Dec. 24, 2018).

State Taxation (3d ed. 2017 rev.) (co-author, with Walter Hellerstein).

Platforms, 86 State Tax Notes 1165 (2017) (co-author, with Walter Hellerstein & Jonathan E. Maddison).

IRC Section 482:  It’s Not Just About Transfer Pricing, 86 State Tax Notes 149 (2017).

The Zombie Precedent:  Norton Co. v. Department of Revenue, 84 State Tax Notes 301 (2017).

Federal Constitutional Limits on State Taxation, in Sales and Use Taxation ___ (2d ed., William Fox ed. 2016).

The Sales Taxation of Amusements, 82 State Tax Notes 909 (2016).

Florida’s (Not So) Bizarre Tax on Florists’ Sales:  A Reply to Brunori, 81 State Tax Notes 189 (2016) (co-author, with Walter Hellerstein).

The Streamlined Sales and Use Tax Agreement in the Courts, 79 State Tax Notes 719 (2016).

Quexit:  The Time Has Come, 81 State Tax Notes 695 (2016).

State Tax Notes:  Striking the Right Chord, 81 State Tax Notes 768 (2016).

Facial State Tax Discrimination Allegedly Causing No Harm, 75 State Tax Notes 749 (2015) (co-author, with Walter Hellerstein).

Reconciling the Marketplace Fairness Act with Origin Sourcing, 75 State Tax Notes 809 (2015).

Are Bees Livestock?:  A Lighthearted Look at Legal Analysis, 77 State Tax Notes 241 (2015).

State and Local Taxation:  Cases and Materials (10th ed. 2014) (co-author, with Walter Hellerstein, Kirk J. Stark, & Joan M. Youngman).

It’s Time to Abandon Retroactive Application of UDITPA Section 18, 73 State Tax Notes 53 (2014).

State Income Taxation of Out-of-State Corporate Partners, 18 Chapman L. Rev. 211 (2014).

State Taxation:  Basic Principles, Checkpoint Catalyst Topic #1001 (2014).

Sales Factor, Checkpoint Catalyst Topic #1007 (2014) (co-author, with Melissa A. Oaks).

State Taxation (3d ed. 2013 rev.).

State Jurisdiction to Tax “Nowhere” Activity, 33 Va. Tax Rev. 209 (2013) (co-author, with Walter Hellerstein).

The Market State Approach to the Attribution of Receipts from Services, 59 State Tax Notes 331 (2011) (co-author, with Walter Hellerstein).

The Questionable Constitutionality of Amazon’s Distribution Center Deals, 62 State Tax Notes 667 (2011) (co-author, with Walter Hellerstein).

Misalignment of Substantive and Enforcement Tax Jurisdiction in a Mobile Economy:  Causes and Strategies for Realignment, 63 Natl. Tax J. 925 (2010).

State and Local Taxation: Cases and Materials (9th ed. 2009) (co-author, with Walter Hellerstein, Kirk J. Stark, & Joan M. Youngman).

Streamlined Sales and Use Tax (5th ed. 2008/2009) (co-author, with Walter Hellerstein).

Classifying State and Local Taxes:  Current Controversies 54 State Tax Notes 35 (2009) (co-author, with Walter Hellerstein).

What Jim Cramer Can Teach us About State and Local Government Finance, 51 State Tax Notes 1049 (2009).

State Taxation, 2009 Cumulative Supplement (3d ed. Supp. 2009) (co-author, with Walter Hellerstein).

Riverboat Gambling and Use Tax Planning:  When to Hold and When to Fold, 53 State Tax Notes 105 (2009).

Streamlined Sales and Use Tax (4th ed. 2007/2008) (co-author, with Walter Hellerstein).

Reforming the State Corporate Income Tax: A Market State Approach to the Sourcing of Service Receipts, 83 Tul. L. Rev. 285 (2008).

Same Questions, Different Answers:  A Comparative Look at International and State and Local Taxation, 50 Ariz. L. Rev. 111 (2008).

Further Thoughts On the ‘Subject to Tax’ Exception in State Corporate Income Tax Expense Disallowance Statutes, 48 State Tax Notes 597 (2008) (co-author, with Walter Hellerstein).

Town Fair Tire and the Silliness of the Physical Presence Rule for Use Tax Collection Nexus, 50 State Tax Notes 447 (2008) (co-author, with Walter Hellerstein).

State Taxation, 2008 Cumulative Supplement (3d ed. Supp. 2008) (co-author, with Walter Hellerstein).

A Brief History of UDITPA, 49 State Tax Notes 759 (2008).

Walter Hellerstein:  The Annotation is in the Grooves, 51 State Tax Notes 91 (2008).

The Federal Role in State Taxation: A Normative Approach, 60 Nat'l Tax J. 611 (2007) (co-author, with William F. Fox).

State Taxation, 2007 Cumulative Supplement (3d ed. Supp. 2007) (co-author, with Walter Hellerstein).

The Sales Taxation of Customer Loyalty Programs, 45 State Tax Notes 717 (2007).

The Pumpkin Tax, 46 State Tax Notes 363 (2007).

Streamlined Sales and Use Tax (3d ed. 2006) (co-author, with Walter Hellerstein).

The Streamlined Sales Tax Project and the Local Sourcing Conundrum, 104 J. Tax'n 230 (2006) (co-author, with Walter Hellerstein).

What Is a "Sale" for Sales Tax Purposes (Part 2)? 40 State Tax Notes 471 (2006).

Local Sales Tax Sourcing and the Streamlining Movement, 41 State Tax Notes 697 (2006).

The Sales and Use Tax Dichotomy and the Streamlining Movement, 43 State Tax Notes 129 (2006).

State Taxation, 2006 Cumulative Supplement (3d ed. Supp. 2006) (co-author, with Walter Hellerstein).

The Wages of Virtue:  Voluntary Registration and Jurisdiction to Tax, 42 State Tax Notes 131 (2006).