George Hani and Jim Gadwood Co-Author 2023-1 Supplement to Leading Treatise on Federal Tax Accounting
Washington, DC, May 23, 2023 – Miller & Chevalier Members George Hani and Jim Gadwood co-authored the first 2023 supplement of Federal Tax Accounting, originally written by firm Senior Counsel Stephen 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:
- Significantly revised ¶ 2.02[e], Financial Statements Do Not Determine Method, including new examples where Congress and/or the U.S. Department of the Treasury (Treasury) have imposed financial statement conformity requirements in connection with specific accounting methods for federal income tax purposes (e.g., the new corporate alternative minimum tax (CAMT), Section 451(b), Last In, First Out (LIFO) conformity, and certain Treasury regulations under Section 263A).
- Fully revised ¶ 4.03, Prepaid Income, to reflect the rules under Section 451(c) and Treas. Reg. § 1.451-8 relating to advance payments and other updates.
- New discussion contrasting the treatment of a check written and delivered before death but cashed after death for income tax purposes and gift tax purposes (Estate of DeMuth v. Commissioner).
- New case addressing the definition of an accounting method change, whether a change in the treatment of property transfers from loans to sales was a change in accounting method, and the Internal Revenue Service's (IRS) discretion to determine whether a taxpayer's accounting method clearly reflects income (Starer v. Commissioner).
- New case addressing the requirements for relief under Section 1341 for computing tax where a taxpayer restores an amount held under a claim of right (Richard J. O'Neill Trust v. Commissioner).
Further information about the treatise and the 2023-1 Supplement can be found here.
About the Authors
George Hani concentrates his practice on the resolution of tax controversies at the administrative level, with a particular focus on tax accounting issues. Prior to joining Miller & Chevalier, Mr. Hani was an Honors Attorney with the General Counsel's office at Treasury. Mr. Hani is active with many bar associations, having served as the Chair of the Tax Section of the DC 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 (SFTI), 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 has a diverse tax practice with specific focuses in federal tax accounting, tax controversy, and transfer pricing advocacy. 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 www.millerchevalier.com.
Laura Miller, Media Relations, Greentarget, 312-252-4104