Required Texts

(1) Taxation of Business Enterprises by Peroni & Bank (Thomson West 4th ed. 2012) (ISBN 978-0-314-19487-9)

(2) Access to the Internal Revenue Code & Regulations in class. I shall be using Selected Federal Taxation—Statutes and Regulations (West 2022 ed.) (ISBN: 9781636592633). If you have access to a used copy of the 2020 or 2021 selected sections book (whether from West or Commerce Clearing House), that should do, as well. While the American Rescue Plan (enacted in March) made a few tax changes, I’ll try to alert you to them so those with an old Code can access (and print) the new language online. I do think working with a hard copy of the Code and regs is helpful. Nevertheless, for those who wish to avoid the cost of purchasing a hard copy, you can access the relevant Code section or Treasury Regulation online by typing the code section (e.g., IRC 61) or treasury regulation (e.g., TR 1.61-2) into your browser’s search box, and the first item to come up will be the Legal Information Institute’s version of the code section or regulation. The LII is hosted by Cornell law school. You will need access in real time in class, so if you do not purchase a hard copy, you will need to bring a laptop to class.

One word of warning, however. Although the final exam is open book, you will not be able to access either the internet or your hard drive during the exam (unlike your Tax I exam), so those of you choosing online access only may wish to print out some of the Code sections and Treasury Regulations that you wish to have with you during the final exam.

Always read the relevant Code provisions and Treasury Regulations before class. Just as important, always try your best to work through the assigned problems before class.  All page references below are to Peroni et al. I may make changes to the syllabus (or distribute additional reading material) throughout the semester. The problems will be covered only if they are specifically assigned below in writing (i.e., they will not be covered, even if they are located on assigned pages, unless the problem is itself specifically assigned).

Some assignments listed to take an entire class may, in fact, take less, while others will take more than the assigned time. In other words, the class assignments below are rough estimates.

I. Taxable Corporate Acquisitions

Class 1: Review from Tax II §§ 351(a); 331(a); 332(a); 336(a); 337(a); 334(a), (b). Read p. 352-68 of the text and §§ 338(a), (d)(3), (h)(3), and (h)(10).

I shall distribute hard copies of the syllaubus on the first day of class, but for those want a sneak peek, I attach it here.