Samuel A. Mitchell -- Publications

Tax Hedge Accounting Matching Principles and Revenue Ruling 2002-71

Tax Hedge Accounting Matching Principles and Revenue Ruling 2002-71, T3: Taxing Times Tidbits, 68 Taxing Times, Vol. 8, Issue 2 (May 2012) (Co-authored with Peter H. Winslow). Click here for Full Text (PDF).

IRS Third-Party Summonses–Negotiated Cooperation Usually is the Best Approach

IRS Third-Party Summonses–Negotiated Cooperation Usually is the Best Approach, 9 Expect Focus, Vol. 2 (Spring 2012). Click Here for Full Text (PDF).

IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine

IRS LB&I Division Issues Guidance to Examiners on the Codified Economic Substance Doctrine, 21 Taxing Times, Vol. 8, Issue 1 (February 2012).  Click here for Full Text (PDF).

Insurance Company Bad Debt

Insurance Company Bad Debt, 19 Taxing Times, Vol. 7, Issue 3 (September 2011) (co-authored with Peter H. Winslow). Click here for Full Text (PDF).

SSAP 43R and Tax Standards for Partial Worthlessness Deductions

SSAP 43R and Tax Standards for Partial Worthlessness Deductions, T3: Taxing Times Tidbits, 27 Taxing Times, Vol. 6, Issue 2 (May 2010) (co-authored with Peter H. Winslow). Click here for Full Text (PDF).

IRS to Require Disclosures of Uncertain Tax Positions

IRS to Require Disclosures of Uncertain Tax Positions, T3: Taxing Times Tidbits, 24 Taxing Times, Vol. 6, Issue 2 (May 2010) (co-authored with Peter H. Winslow). Click here for Full Text (PDF)

REMIC Impairments May Qualify as Worthless Bad Debts

REMIC Impairments May Qualify as Worthless Bad Debts, T3: Taxing Times Tidbits, 50 Taxing Times, Vol. 5, Issue 2 (May 2009) (Co-authored with Peter H. Winslow). Click here for Full Text (PDF)

Appeals Court Affirms Textron (or not)

Appeals Court Affirms Textron (or not), T3: Taxing Times Tidbits, 48 Taxing Times, Vol. 5, Issue 2 (May 2009) (Co-authored with Peter H. Winslow). Click here for Full Text (PDF)

Tax Aspects of Nonperforming Assets

Tax Aspects of Nonperforming Assets, 28 Taxing Times, Vol. 4, Issue 3 (September 2008) (Co-authored with Peter H. Winslow). Click here for Full Text (PDF)

Highest Aggregate Reserves Qualify for Statutory Reserves Cap

Highest Aggregate Reserves Qualify for Statutory Reserves Cap, T3: Taxing Times Tidbits, 38 Taxing Times, Vol. 4, Issue 3 (September 2008) (co-authored with Lori J. Jones and Peter H. Winslow). Click here for Full Text (PDF)