Howard E. Abrams

Professor of Law 

Curriculum Vitae

 

 

Areas of Expertise
Contracts, Partnership Taxation, Federal Income Taxation: Individuals

Biography

Howard E. Abrams graduated from the University of California at Irvine in 1976 and, after a year of graduate study in mathematical physics, he attended Harvard Law School. Graduating in 1980, Professor Abrams clerked for Chief Judge Tannenwald of the United States Tax Court and practiced for a short while with the Los Angeles office of Brobeck, Phleger & Harrison.

Professor Abrams joined the Emory Law faculty in 1983 and now teaches Contracts, Fundamentals of Income Taxation and Partnership Taxation. Professor Abrams has taught at Berkeley (Boalt Hall), Cornell Law School, the University of Oklahoma School of Law, Georgia Law School and Leiden University in the Netherlands. In Spring 2009 he was the Maurice R. Greenberg Visiting Professor at Yale Law School. During the 1999-2000 academic year, Professor Abrams was the Director of Real Estate Tax Knowledge at Deloitte & Touche LLP in Washington, D.C. Professor Abrams also spent 2003 in residence at Steptoe & Johnson LLP in Washington, D.C.

Professor Abrams is the author or co-author of four books: Federal Income Taxation of Corporations and Partnerships, Federal Corporate Taxation, Essentials of U.S. Taxation and Federal Income Taxation of Partnerships and Other Pass-Thru Entities. His articles have appeared in the Harvard Law Review, the Tax Law Review, the Tax Lawyer, the Virginia Tax Law Review, Tax Notes and other periodicals. Professor Abrams has on four occasions been recognized for excellence in teaching.

Education: BA, University of California-Irvine, 1976; JD, Harvard University, 1980.

Howard E. Abrams

Publications

FEDERAL INCOME TAXATION OF CORPORATIONS AND PARTNERSHIPS, Aspen Law & Business (4th ed. 2009, co-authored with R. Doernberg and D. Leatherman).

FEDERAL CORPORATE TAXATION, Foundation Press (6th ed. 2008, co-authored with R. Doernberg).

DISREGARDED ENTITIES, 704-1 BNA Tax Management Portfolio Series (2007, coauthored with F. Witt & L. Zarlinga).

ESSENTIALS OF UNITED STATES TAXATION, Kluwer Law International (1999, coauthored with R. Doernberg).

FEDERAL INCOME TAXATION OF PARTNERSHIPS AND OTHER PASS-THRU ENTITIES, Anderson Press (1993).

Partnership Book-Ups, 127 TAX NOTES 435 (April 26, 2010).

Partnership COD Income and Other Debt Issues, 126 TAX NOTES 845 (February 15, 2010).

Partnership Use of Disregarded Entities, 25 TAX MGMT. REAL ESTATE J. 155 (2009).

Now You See It, Now You Don't: Exiting a Partnership and Making Gain Disappear, 50 TAX MGMT. MEM. 75 (2009).

Taxation of Carried Interests: The Reform That Did Not Happen, 40 LOYOLA L.J. 199 (2009).

Disposition and Partial Disposition of a Partnership Interest, 11 JOURNAL OF PASSTHROUGH ENTITIES 31 (2008).

The Past is Prologue: Carried Interests, 24 TAX MGMT. REAL ESTATE J. 23 (2008).

A Close Look at the Carried Interest Legislation, 117 TAX NOTES 961 (Dec. 3, 2007).

Partnership Allocation of Selected Real Estate Tax Credits, 23 TAX MGMT. REAL ESTATE J. 206 (2007).

Taxation of Carried Interests, 116 Tax Notes 183 (July 16, 2007), reprinted in 23 TAX MGMT. REAL ESTATE J. 199 (2007).

Recommendations on Modernizing Section 751(b), 22 TAX MGMT. REAL ESTATE J. 218 (2006).

New Rules Limit Flexibility on Withholding by Disregarded Entities, 21 TAX MGMT. REAL ESTATE J. 362 (2005).

How to Shoehorn a Disregarded Entity's Discharge of Indebtedness Into Section 108 Relief for Its Owner, 21 TAX MGMT. REAL ESTATE J. 351 (2005).

JCT Proposal on Partnership Nonrecourse Debt Unwarranted, 108 TAX NOTES 1301 (Sept. 12, 2005), reprinted in 21 TAX MGMT. REAL ESTATE J. 315 (2005).

The Truth About Partnership Debt. Guaranteed, 21 TAX MGMT. REAL ESTATE J. 59 (2005).

Simple Distributions from Leveraged Partnerships, 1 PITT. TAX L. REV. 131 (2004).

Section 704(c) Gain in Partnership Mergers, BUSINESS ENTITIES 34 (May-June 2004).

The Section 734(b) Basis Adjustment Needs Repair, 57 TAX LAWYER 343 (2004).

Using Cash and Carried Interests in a Real Estate Partnership, 31 REAL ESTATE TAXATION 52 (First Quarter 2004), reprinted in 20 TAX MGMT. REAL ESTATE J. 329 (2004).

New Changes to the At-Risk Rules, 6 JOURNAL OF PASSTHROUGH TAXATION 37 (Sept.-Oct. 2003).

Applying the Unrelated Debt-Financed Income Rules to Investments in Real Property, 15 TAXATION OF EXEMPTS 3 (July-Aug. 2003) (with S. McDowell).

Reverse Allocations: More than Meets the Eye, 5 JOURNAL OF PASSTHROUGH ENTITIES 35 (Sept.-Oct. 2002).

Adding a New Cash Partner to an Operating Partnership (pt. 2), BUSINESS ENTITIES 38 (March-April 2002).

Adding a New Cash Partner to an Operating Partnership (pt. 1), BUSINESS ENTITIES 28 (Jan.-Feb. 2002).

Implications of Estate Tax Repeal and Carryover Basis for Real Estate Owners, 91 TAX NOTES 511 (2001).

Getting Out Without Selling Out: The Proposed Partnership Merger and Division Regulations, 59 N.Y.U. INST. FED. TAX. §11 (2001).

Dealing With the Contribution of Property to a Partnership (pt. 2), BUSINESS ENTITIES 18 (Jan.-Feb. 2001).

Dealing With the Contribution of Property to a Partnership (pt. 1), BUSINESS ENTITIES 16 (Nov.-Dec. 2000).

Revenue Ruling Suggests Strategic Partnership Failure to Book-Up, 2000 THE TAX ADVISOR 159 (March 2000).

Congress Repeals Installment Reporting for Accrual Taxpayers, 2000 THE TAX ADVISOR 142 (March 2000).

Doing the McCauslen Two-Step, BUSINESS ENTITIES 18 (Nov.-Dec. 1999).

Judge Tannenwald on the Tax Court: An Enduring Legacy of Fundamental Fairness, 48 EMORY L.J. 863 (1999).

Issues and Strategies in Exiting Partnerships, 57 N.Y.U. INST. FED. TAX. §11 (1999).

How Electronic Commerce Works, TAX NOTES INT’L (May 12, 1997).

An Introduction to the US Taxation of Limited Liability Companies, 1995 FISKAAL 223.

Cancellation of Indebtedness Income, 1992 FISKAAL 96.

Economic Analysis and Unconstitutional Conditions: A Reply to Professor Epstein, 27 U. SAN DIEGO L. REV. 359 (1990).

The New Section 752 Regulations: A Rejoinder, 48 TAX NOTES 1056 (1990).

Long Awaited Regulations Under Section 752 Provide Wrong Answers, 44 TAX L. REV. 627 (1989).

Equitable Implementation of Tax Expenditures, 9 VA. TAX REV. 109 (1989) (coauthored with J. Edrey).

Rethinking Generation-Skipping Transfers, 40 SW. L.J. 1145 (1987).

Rethinking Tax Transitions: A Reply to Dr. Shachar, 98 Harv. L. Rev. 1809 (1985).

Book Review: The Theory of Dispute Resolution, 37 OK. L. REV. 437 (1984).

A Re-Evaluation of the Terminable Interest Rule, 39 TAX L. REV. 1 (1983).

Systemic Coercion: Unconstitutional Conditions in the Criminal Law, 72 J. CRIM. L. & CRIM. 128 (1981).

Howard E. Abrams