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George Hani and Jim Gadwood Co-Author 2022-2 Supplement to Leading Treatise on Federal Tax Accounting

Washington, DC, December 8, 2022 – Miller & Chevalier Tax Department Vice Chair George Hani and Tax Member Jim Gadwood have co-authored the second 2022 supplement of Federal Tax Accounting, originally authored by firm Senior Counsel Steve Gertzman and published by Warren, Gorham & Lamont (a Thomson Reuters company). Federal Tax Accounting is generally recognized as the leading authority on the topic and is used by many colleges, universities, and law schools. 

The newly released supplement includes the following:

  • A new section on the treatment of advance payments under Section 451(c) and the final regulations recently issued thereunder, including a discussion of:
    • the definition of an advance payment
    • the full-inclusion method, AFS deferral method, and non-AFS deferral method
    • the advance payment cost offset method available for advance payments relating to the sale of inventory
    • special rules that apply to specified goods; and 
    • related changes in accounting method.
  • Discussion of a recent case addressing the clear reflection of income doctrine (Continuing Life Communities Thousand Oaks LLC v. Commissioner).
  • Discussion of recent case addressing the application of the economic performance rule that applies in the context of a sale or exchange of a trade or business (Hoops LP v. Commissioner).
  • A citation to Rev. Proc. 2022-14, which provides the consolidated list of accounting method changes that are eligible for the automatic consent procedures.

Further information about the treatise can be found here

About the Authors

George Hani is a Member of Miller & Chevalier Chartered and concentrates his practice on the resolution of tax controversies at the administrative level, with a particular focus on tax accounting issues. Prior to joining the firm, Mr. Hani was an Honors Attorney with the General Counsel's office at the U.S. Department of the Treasury. Mr. Hani is active with many bar associations, having served as the Chair of the Tax Section of the District of Columbia Bar, the Chair of the Administrative Practice Committee of the Taxation Section of the American Bar Association (ABA), and a Council Director of the Taxation Section of the ABA. He is a trustee of the Southern Federal Tax Institute, a member of the Advisory Board of the Texas Federal Tax Institute, and a Fellow of the American College of Tax Counsel. He is routinely recognized by Chambers USA, Legal 500, and the International Tax Review. He writes and speaks frequently on federal tax accounting topics.

Jim Gadwood is a Member of Miller & Chevalier Chartered in Washington, DC. He has a diverse tax practice and focuses on federal tax accounting, transfer pricing, and federal civil tax controversies. He speaks and writes frequently on a variety of federal tax matters. Mr. Gadwood earned his law degree from Boston University School of Law and a degree in economics from the University of Michigan.

About Miller & Chevalier 

Founded in 1920, Miller & Chevalier is a Washington, DC law firm with a global perspective and leading practices in Tax, International Law, Litigation, ERISA, White Collar Defense and Internal Investigations, Government Contracts, and Government Affairs. Miller & Chevalier is a top-ranked firm sharply focused on targeted areas that interact with the federal government. A significant number of firm lawyers have held senior positions in the U.S. government and have written many of the regulations they currently help clients navigate. For more information on the firm, visit  


Laura Miller, Media Relations, Greentarget, 312-252-4104