All of Stephen's Publications

Stephen was Counsel of Record in an amicus curiae brief in support of the government that was acknowledged by Justice Kavanaugh in his decision.

The first version of this article was published in The Tax Lawyer under the title “Partnership Revaluations.”

I had the feeling, and still do, that the growth of derivatives poses a serious challenge to the tax law’s attempt to tax different classes of income differently

This was one of the first occasions for the use of the “Pac-Man” defense, where the target launches a counterattack by buying shares of its purported acquirer.

Even when tax rates are stable, there is an economic benefit to deferring payment of tax, which is worth as much as a complete exemption of the return on the tax deferred.