JONI LARSON (cell)

JONI LARSON

WORK EXPERIENCE

INDIANA TECH LAW SCHOOL August 2015 - Present Professor of Law. Teach Federal Income Tax and Trust, Wills and Estates. WESTERNMICHIGANUNIVERSITY-COOLEYLAWSCHOOL

August 2002 – August 2015 Professor of Law, Director of the Graduate Tax Program, Department Chair. Taught Individual Income Tax and Business Organizations in the J.D. program and Partnership Tax, Tax Research and Argument, Tax Practice and Procedure, and Standards and Ethics in the Graduate Tax Program.

Served on the Promotion & Tenure Committee and Curriculum Committee.

OFFICE OF CHIEF COUNSEL September 1998 - July 2002 Executive Assistant to Division Counsel (Small Business/Self-Employed). Assisted Division Counsel by reviewing regulation projects, responding to Congressional inquires, and coordinating substantive issues with field attorneys, including family limited partnership litigation, coal excise tax refunds, and tax shelter litigation. Previously, was an attorney with the Passthroughs & Special Industry Branch of the Field Service Division and assisted District Counsel attorneys in preparing issues for litigation, drafted Chief Counsel Advice, reviewed briefs and motions, and prepared settlement letters.

ANDERSON HUNTER LAW FIRM January 1996 - September 1998 Associate Attorney. Practiced in the areas of estate planning, probate, business succession planning; pension and profit sharing plans; and individual tax planning. OFFICE OF CHIEF COUNSEL September 1992 - December 1995 Tax Litigation Attorney for District Counsel. Reviewed statutory notices of deficiency, answered petitions, engaged in informal and formal discovery, prepared and litigated cases, wrote briefs, and rendered legal advice to the Examination Division.

UNITED STATES TAX COURT August 1990 - July 1992 Attorney-Adviser to Judge Irene F. Scott. Researched tax issues; prepared and reviewed numerous opinions, including Ithaca Industries, Inc. v. Commissioner, 97 T.C. 253 (1991), aff'd, 17 F.3d 684 (4th Cir. 1994).

ADDITIONAL TEACHING EXPERIENCE

GEORGETOWN UNIVERSITY September 2000 – August 2002 Adjunct Professor. Taught Tax Research in LL.M. in Taxation program. Acted as adviser for Supervised Elective Research.

CATHOLICUNIVERSITY OF AMERICA January 2001- May 2001 Adjunct Professor. Taught Partnership Tax in J.D. program.

GOLDEN GATE UNIVERSITY May 1997 - September 1998 Adjunct Professor. Taught Individual Tax and Research and Writing for M.S. in Taxation program.

ST. MARY'S UNIVERSITY SCHOOL OF LAW January 1995 - June 1995 Adjunct Professor. Taught Tax Litigation in J.D. program, with emphasis on skills necessary to represent a client before the Internal Revenue Service and the United States Tax Court.

EDUCATION

MICHIGAN STATE UNIVERSITY East Lansing, Michigan

Degree: Master of Arts in Educational Technology (2008) UNIVERSITY OF FLORIDA COLLEGE OF LAW

Gainesville, Florida

Degree: LL.M. in Taxation (1990)

UNIVERSITY OF MONTANA SCHOOL OF LAW Missoula, Montana

Degree: Juris Doctorate (1989) UNIVERSITY OF MONTANA

Missoula, Montana

Degree: Bachelor of Arts in Economics (minor in Mathematics) (1986)

PUBLICATIONS Books:

 PROBLEMS AND SOLUTIONS IN PARTNERSHIP TAX (Carolina Press, 2013)

 INDIVIDUAL INCOME TAXATION: AN APPLICATION APPROACH (Carolina Academic Press, 2013)

 VALUATION HANDBOOK (LexisNexis, updated annually)

 PARTNERSHIP TAXATION: AN APPLICATION APPROACH (2d Ed.) (Carolina Academic Press, 2013)

 FEDERAL TAX RESEARCH (2d Ed.) (with Dan Sheaffer, Carolina Academic Press, 2011)

 NATIONAL OFFICE PRACTICE (on-line publication, 2d ed. 2009; CCH)

Treatise Chapters:

 Consolidated Tax Returns, MERTENS LAW OF FEDERAL INCOME TAXATION (2014)

 Life Insurance Companies, MERTENS LAW OF FEDERAL INCOME TAXATION (2014)

 Original Issue Discount and Imputed Interest, MERTENS LAW OF FEDERAL INCOME TAXATION (2013)

 Real Estate Investment Trusts, MERTENS LAW OF FEDERAL INCOME TAXATION (2011)

 Methods of Accounting, MERTENS LAW OF FEDERAL INCOME TAXATION (2011)

 Passive Activity Loss Rule, MERTENS LAW OF FEDERAL INCOME TAXATION (2011)

 At-Risk Limitations, MERTENS LAW OF FEDERAL INCOME TAXATION (2010)

 Exclusions from Income, MERTENS LAW OF FEDERAL INCOME TAXATION (2009)

 Compensation, MERTENS LAW OF FEDERAL INCOME TAXATION (2007)

 Bad Debts (Matthew Bender, on-line treatise; 2006)

 Disallowed Losses (Matthew Bender, on-line treatise; 2006)

 Deficiencies and Tax Court Litigation, FEDERAL TAX PRACTICE AND PROCEDURE (LexisNexis)

Law Review Articles:

 To Develop Critical Thinking Skills and Allow Students to Be Practice-Ready, We Must Move Well Beyond the Lecture Format (pending acceptance)

 Turning the Tables: Is it Time for Professors to Stop Fighting the Presence of Students’ Technology in the Classroom and Instead Use it to Enhance Student Learning? (pending acceptance)

 Tax Evidence: A Primer on the Federal Rules of Evidence as Applied by the Tax Court, Vol. 66, No. 3 THE TAX LAWYER 733 (Spring 2013)

 Using Faculty Inquiry Process to Examine Student Responsibility for Learning, 61 J. LEGAL EDUC. 280 (2011) (with Tonya Krause-Phelan et al.)

 Tax Evidence III: A Primer on the Federal Rules of Evidence as Applied by the Tax Court, Vol. 62, No. 3 THE TAX LAWYER 555 (Spring 2009)

 The Intersection of Andragogy and Distance Education: Handing Over the Reins of Learning to Better Prepare Students for the Practice of Law, VOL. 9, NO. 2 THOMAS M. COOLEY JOURNAL OF PRACTICAL AND CLINICAL LAW 117 (2007)

 Tax Evidence: A Primer on the Federal Rules of Evidence as Applied by the Tax Court, Vol. 32, No. 2 TEXAS TAX LAWYER 31 (Feb. 2005)

 Tax Evidence II: A Primer on the Federal Rules of Evidence as Applied by the Tax Court, 57 THE TAX LAWYER 371 (2004)

 Burden of Proof in the Tax Court After Shea and the IRS Restructuring and Reform Act of 1998, 36:1 GONZAGA UNIVERSITY LAW REVIEW 49 (2000/01)

 Tax Evidence: A Primer on the Federal Rules of Evidence as Applied by the Tax Court, 53 THE TAX LAWYER 181 (1999)

 When Fifth Circuit Disregards Factual Findings of Tax Court, Erroneous Result is Reached in G.M. Trading Corporation v. Commissioner, 27 CAPITAL UNIVERSITY LAW REVIEW 317 (1999), reprinted in DIGEST OF TAX ARTICLES, Oct. 1999, at 53

 The Bankruptcy Court Overlooks Tax Law in In Re Prudential Lines, Inc.: An NOL Should Not Be Property of a Bankruptcy Estate, 29 WILLAMETTE LAW REVIEW 23 (1993)

Journal Articles:

 Disproportionate Distributions: Easier Under the Proposed Regs?, Vol. 147, No. 7 TAX NOTES 787 (Feature article, May 18, 2015)

 Bitcoin: Same Song, Second Verse, A Little Bit Louder and a Little Bit Worse, Vol. XLI, Issue 1 MICHIGAN TAX LAWYER 34 (Winter 2015), State Bar of Michigan

 Compensatory and Noncompensatory Partnership Interests and Those

Transactions That Fail to Meet the Section 721 Non-Recognition Provision (with Catherine McCollum), First Annual Mark R. Solomon Tax Symposium, Vol. 1 (Sept. 2013)

 Teaching Outside the Box: Focus on Learning, THE LAW TEACHER (Fall 2008) (with Vicki Eggers);article included in TECHNIQUES FOR TEACHING LAW 2, Friedland, Hess, Schwartz, and Sparrow

 Collection Due Process: When is a Hearing Worth Pursuing?, Vol. 32, No. 2 MICHIGAN TAX LAWYER 15 (Summer 2006), State Bar of Michigan

 The IRS’s Push Towards Settlement, 83 MICHIGAN TAX LAWYER 34 (Nov. 2004), State Bar of Michigan

 Focus on the IRS National Office, 6 JOURNAL OF TAX PRACTICE AND PROCEDURE 35 (April-May 2004)

 What Attorneys Should Know if Their Client is Being Audited by the IRS, 21THE MONTANA LAWYER 10 (1996).

 Tax Law and Compensation for Injuries, Sickness, 20 THE MONTANA LAWYER 4 (1994)

 What Divorce Attorneys Need to Know About Tax Law, 18 THE MONTANA LAWYER 3 (1993)

Seminar/Training Materials:

 Consolidated Returns: Overview (CCH Tax Research Network, 2015)

 Limited Liability Companies: Traps and Opportunities (CCH Tax Research Network, 2015)

 Divorce and Taxes: Tax Consequences of Alimony and Separate Maintenance Course (CCH Tax Research Network, 2015)

 Internal Controls (Tax Research Consultant/LexisNexis, 2008)

 Insider Trading (Tax Research Consultant/LexisNexis, 2008)

 Whether To Go Private (Tax Research Consultant/LexisNexis, 2008)

 Innocent Spouse and Filing Issues (CCH Tax Research Network)

 Property Transfers During Marriage or Incident to Divorce (CCH Tax Research Network)

 Tax Consequences of Alimony and Separate Maintenance (CCH Tax Research Network)

 Individual Stages: Adults Later in Life (CCH Explanations and Analysis – Tax Research Consultant, online resource, 2007)

 Individual Stages: Retired Adults (CCH Explanations and Analysis – Tax Research Consultant, online resource, 2007)

 Retirement Planning Stages: Qualified Retirement Plans (Defined Contribution Plans) (CCH Explanations and Analysis - Tax Research Consultant, online resource, 2007)

 Retirement Planning Stages: Money Purchase Pension Plans (CCH

Explanations and Analysis - Tax Research Consultant, online resource, 2007)

 Child-Related Issues of Divorce (CCH Tax Research Network)

 At the Intersection of Internal Controls: Putting the Pieces Together in a

Meaningful Way, ethics presentation before the Lansing/Jackson chapter of the Institute of Managerial Accountants (IMA) (2006)

 Tool – Amortization of Start Up Expenses (Tax Research Consultant)

 Tool – Section 179 Bonus Depreciation (Tax Research Consultant)

 Tool – Casualty Loss (Tax Research Consultant)

 Circular 230, presentation before Michigan Practitioner Liaison Group (2006)

 Amortization Rules (CCH Tax Research NetWork)

Speaking Engagements

 Digital Currency: Following the Tax Consequences, (presenter at the Michigan Bar Association’s 28th _{Annual Tax Conference, 2015)}

 The Rules of Evidence and the Tax Court (Webinar sponsored by Bloomberg BNA, 2013)

 Compensatory and Noncompensatory Partnership Interests and Those

Transactions That Fail to Meet the Section 721 Non-Recognition Provision (with Catherine McCollum), First Annual Mark R. Solomon Tax Symposium (2013)

 Common Evidentiary Issue in Tax Cases (panel discussion, American Bar Association, Section of Taxation, Fall 2011)

 Tax Aspects of Workouts and Bankruptcies (presenter at the Michigan Bar Association’s 24th _{Annual Tax Conference, 2011)}

 Common Evidentiary Issue in Tax Cases (panel discussion, American Bar Association, Section of Taxation, Spring 2011)

 Valuation of Stock Where Corporation Holds Appreciated Assets (Webinar sponsored by LexisNexis, 2010)

 Collection Due Process (presenter at the Michigan Bar Association’s 19th _Annual

Tax Conference, 2006)

 Entity Selection (presenter at the Michigan Bar Association’s 18th _{Annual Tax}

Conference, 2005)

 Estate Planning for Elder Clients (presenter at the University of Montana Law School’s 45th _{Annual Tax Institute, 1997)}

U.S. Supreme Court Amicus Curiae Brief

 Stocker v. United States (filed September 30, 2013)

Blog Postings

 New Notice Requirement for Issuing Non-Party Subpoenas Read Into the Tax Court Rules [Procedurally Taxing Blog]

 The Tax Court Continues It’s Now-We-See-It-Now-We-Don’t Treatment of the Commissioner’s Substitute for Return [Procedurally Taxing Blog]

 If You Are Just Getting Around to Mailing Your Tax Return, You Might Want to Send it Registered or Certified Mail [WMU-Cooley Blog]

 Proposal to Amend Section 7453 to Provide that the Tax Court Apply the Federal Rules of Evidence [Procedurally Taxing Blog]

BAR ADMISSIONS

 United States Supreme Court

 Montana

 Washington State

 Washington, D.C.

 Michigan