Jack Townsend’s Publications

* Tax Crimes 2d Edition (Lexis‐Nexis 2015), here, a publication in the Lexis‐Nexis Graduate Tax Series. Mr. Townsend co‐authored this book with Larry Campagna (a leading Houston practitioner), Steve Johnson (professor at University of Nevada, Las Vegas) and Scott Schumacher (Assistant Professor, University of Washington School of Law). The book is designed for the student and, for teachers, there is a Teacher’s Manual.

Chapter 12 on Tax Crimes in Michael Saltzman and Leslie Book, IRS Practice and Procedure (Thomsen Reuters 2015), here,  Mr. Townsend was the principal draftsman of Chapter 12 in this seminal treatise.

* Federal Tax Procedure, revised and published twice annually, is the book for a course on Tax Procedure taught by Adjunct Professor Townsend at the University of Houston School of Law. The book and related materials contain text discussion, relevant Code Sections, and certain cases designed to encourage students to think about the Tax Procedure process. The book is in electronic format (Adobe Acrobat pdf format) and is in two versions ‐‐ (1) a footnoted version suited for practitioners and (2) a nonfootnoted version, suited for students and teaching.  The pdf versions are updated every August for use in that year’s Fall class and then every January or February. The updated versions are on Mr. Townsend’s SSRN web page, here.  The books have a companion electronic file (also Adobe Acrobat) consisting of materials such as forms, publications, selected excerpts from congressional committee reports, and limited practice forms available on Professor Townsend’s Federal Tax Procedure Blog.

Federal Tax Crimes, a self‐published pdf text that started out many years ago for the University of Houston course on Tax Fraud and Money Laundering co‐taught by Mr. Townsend at the University of Houston School of Law. The earlier book morphed, substantially revised and shortened into the Lexis‐Nexis Tax Crimes book noted above, particularly suited for teaching. In 2015, Mr. Townsend was the principal draftsman for Chapter 12 on Tax Crimes in Michael Saltzman and Leslie Book, IRS Practice and Procedure (Thomsen Reuters 2015), and discontinued this pdf publication on Federal Tax Crimes.  The latest pdf version of that discontinued publication may be downloaded from Mr. Townsend’s Scholarly Papers Site on SSRN here.

Theories Criminal Tax Sentencing: Fairness and Deterrence: Tax Evaded in the Federal Tax Crimes Sentencing Process and Beyond, 59 Vill. L. Rev. 599 (2014).

* Theories of Criminal Liability for Tax Evasion (May 15, 2012) This is downloadable from the SSRN web site here.

* Making Voluntary Disclosure to the IRS (May 15, 2012) This is downloadable from the SSRN web site here.

* Scoping the Conspiracy, 123 Tax Notes 1047 (May 25, 2009)

* Tax Obstruction Crimes: Is Making the IRS’s Job Harder Enough?, 9 HOUS. BUS. & TAX L.J. 260 (2009).

* Judge Posner’s Opinion in Kikalos, 108 Tax Notes 593 (Aug. 1, 2005)

* Collateral Estoppel in Civil Cases Following Criminal Convictions, 2005 TNT 4-28 (1/6/05).

* Tax Treaty Interpretation, 55 Tax Lawyer 219 (Fall 2001).

* Burden of Proof in Tax Cases: Valuations and Ranges, 93 Tax Notes 101 (2001), 2001 TNT 187-37 (2001).

* Taxpayer Rights in Criminal Investigations, 90 Tax Notes 1842 (3/26/2001), 2001 TNT 52-63 (3/16/2001), 30 Tax Practice No. 1, p. 1 (April 2, 2001).

* The Accountant’s Role – and Risks – in Koveling, 2 Tax Practice & Procedure No. 4 p. 20 (Aug-Sept. 2000).

* Natwest May Be the Law, But Is It Right?, published in each of the following Tax Analysts publications: 84 Tax Notes 772 (8/2/99); Tax Notes Int’l, July 26, 1999, p. 417; and Tax Notes Today 1999 TNT 147-80 (8/2/99)..

* Reconciling Section 482 and the Nonrecognition Provisions, 50 Tax Lawyer 701 (Summer 1997)

* Interpreting Consents to Extend the Statute of Limitations (co-authored with his partner, Larry Jones), 78 Tax Notes 459 (1/26/98)

* Audits and Appeals: Developments, 54 N.Y.U. Institute on Federal Taxation, ch. 26 (1996);

* Section 6103 and the Use of Third Party Tax Return Information in Tax Litigation, 46 Tax Lawyer 923 (Summer 1993) (primarily dealing with exploiting opportunities in transfer pricing disputes)

* IRS Appeals and the Art of Persuasion, 3 IRS Practice & Policy Tax Management Bulletin (No. 2) 42 (November 13, 1992)

* Procter & Gamble and Beyond, 44 The Tax Executive 17 (Jan.-Feb. 1992) (co-authored with a former partner) (the First Security/Aramco Advantage issue)

* The Controversy Over Campbell; Slicing the Bologna Too Thin, 52 Tax Notes (No. 1) 83 (July 1, 1991) (the service partner issue that has gained much attention recently in the context of hedge and private equity funds compensation; Mr. Townsend’s interest in this area is based on his having successfully handled the Government appeal in Diamond v. Commissioner, 492 F.2d 286 (7th Cir. 1974), which is the leading case in the area).