Course Schedule

This is a one-semester three-unit course about substantive federal criminal law. This course will detail the prosecution and defense of criminal offenses in federal court, focusing on the more frequently employed and complex areas, and on current hot topics. Class time will be devoted to mail, wire, bank, and health care fraud, public corruption, money laundering, administration of justice offenses, the Controlled Substances Act, immigration offenses, and terrorism and weapons offenses. Students will be alerted to the manner in which federal sanctions can be employed against lawyers, banks, and corporations, and the bases of federal criminal jurisdiction. If time permits, we will review the federal plea bargaining and sentencing systems. Your grade will be based primarily upon a floating open-book essay exam, and in small part upon class participation.  If we have no more than 14 students, the grade in this class will not be on a curve, and you will be required to complete at least one in-class group project. Second-year students interested in the United States Attorney’s Office or Federal Public Defender's Service internships for their third year should consider taking this class first. This class does not significantly overlap with my Advanced Federal Criminal Prosecution & Defense seminar, Judge Pitman's Fed. Crim. Law seminar, or Mr. DeGuerin's Adv. Fed. Defense seminar.

This is a one-semester three-unit course about substantive federal criminal law. This course will detail the prosecution and defense of criminal trials in federal court, focusing on the more frequently employed and complex areas, and on current hot topics. Class time will be devoted to mail, wire, and health care fraud, public corruption, money laundering, administration of justice offenses, the Controlled Substances Act, immigration offenses, and terrorism and weapons offenses. In addition, students will be alerted to the manner in which federal sanctions can be employed against lawyers, banks, and corporations. If time permits, we will review defenses and the plea bargaining and sentencing systems. Your grade will be based primarily upon a floating open-book essay exam, and in part upon class participation.  If we have no more than 20 students, the grade in this class will not be on a curve, and you will be asked to complete one or two in-class oral projects. Second-year students interested in the United States Attorney’s Office or Federal Public Defender's Office internships for their third year should consider taking this class first. This class does not significantly overlap with the Advanced Federal Criminal Prosecution & Defense seminar, and students are welcome to take both.

This course examines the federal wealth transfer tax system, including the estate and gift taxes; in particular, their application to a wide variety of gratuitous transfers, both lifetime and testamentary. In the case of the gift tax, it considers the concept of a "transfer of property by gift," complete and incomplete transfers, the annual exclusion, and gift-splitting. In the case of the estate tax, it considers the concept of "gross estate," including interests still owned at death, property transferred during life subject to retained interests or powers or in contemplation of death, property subject to powers of appointment, jointly owned property, life insurance, and annuities and employee death benefits. As to both the gift tax and the estate tax, it focuses heavily on the marital and charitable deductions, the unified credit, and problems of valuation. Throughout, it relates the material under consideration to basic, and sometimes not-so-basic, estate planning, including the creation of trusts, both revocable and irrevocable. Prerequisite/Co-requisite: Wills & Estates. FIT is NOT a prerequisite. Related Course Areas Property, Tax

This course examines the federal wealth transfer tax system, including the estate, gift, and generation-skipping taxes; in particular, their application to a wide variety of gratuitous transfers, both lifetime and testamentary. In the case of the gift tax, it considers the concept of a "transfer of property by gift," complete and incomplete transfers, the annual exclusion, and gift-splitting. In the case of the estate tax, it considers the concept of "gross estate," including interests still owned at death, property transferred during life subject to retained interests or powers or in contemplation of death, property subject to powers of appointment, jointly owned property, life insurance, and annuities and employee death benefits. As to both the gift tax and the estate tax, it focuses heavily on the marital and charitable deductions, the unified credit, and problems of valuation. It also considers the generation-skipping tax, but in much less detail. Throughout, it relates the material under consideration to basic, and sometimes not-so-basic, estate planning, including the creation of trusts, both revocable and irrevocable. Prerequisite/Co-requisite: Wills & Estates. FIT is NOT a prerequisite. Related Course Areas Property, Tax

This two-hour course examines Federal income taxation of estates, trusts, grantors, and beneficiaries, as prescribed by Subchapter J of the Internal Revenue Code. In particular, this course focuses on how the income taxation of estates and trusts differs from that of individuals. Central topics include distributable net income (DNI), the distribution deduction, the grantor trust rules, and income in respect of a decedent (IRD). This is an advanced course that assumes familiarity with basic principles of Federal income taxation and the law of wills and estates.

Prerequisite: LAW 293Q, 393Q, 493Q, 593Q or 254J, 354J, 454J, 554J. Federal Income Taxation.

This two-hour course examines Federal income taxation of estates, trusts, grantors, and beneficiaries, as prescribed by Subchapter J of the Internal Revenue Code. In particular, this course focuses on how the income taxation of estates and trusts differs from that of individuals. Central topics include distributable net income (DNI), the distribution deduction, the grantor trust rules, and income in respect of a decedent (IRD). This is an advanced course that assumes familiarity with basic principles of Federal income taxation and the law of wills and estates.

Prerequisite: LAW 293Q, 393Q, 493Q, 593Q or 254J, 354J, 454J, 554J. Federal Income Taxation.

Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.

Required Textbooks:

(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0

(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2025-2026 ed.) OR Selected Federal Taxation Statutes and Regulations, 2026, Daniel J. Lathrope (West Academic 2025)

Recommended Textbooks (Optional):

(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press) (Concepts and Insights Series)

(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic) (Concise Hornbook Series)

(3) Alstott, Income Taxation in Six Concepts (Core Concepts Series) (Foundation Press 2025) (ISBN No. 9798892092821)

This course uses a problem-based method to study core federal income tax doctrine.  It explores the policy choices presented by an income tax system, including equity, efficiency, administration, and political considerations.  Federal Income Tax develops the universal lawyering skill of working with a core statute in conjunction with administrative guidance and cases.  The course is a gateway to further tax offerings.

Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.

Required Textbooks:

(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0

(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2025-2026 ed.) OR Selected Federal Taxation Statutes and Regulations, 2026, Daniel J. Lathrope (West Academic 2025)

Recommended Textbooks (Optional):

(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press) (Concepts and Insights Series)

(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic) (Concise Hornbook Series)

(3) Alstott, Income Taxation in Six Concepts (Core Concepts Series) (Foundation Press 2025) (ISBN No. 9798892092821)

Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.

Required Textbooks:

(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0

(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2024-2025 ed.) OR Selected Federal Taxation Statutes and Regulations, 2025, Daniel J. Lathrope (West Academic 2025)

Recommended Textbooks (Optional):

(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press) (Concepts and Insights Series)

(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic) (Concise Hornbook Series)

This is a four-credit course. There are no prerequisites. No prior background in accounting, economics, math, or finance is needed or expected.

Federal Income Tax (FIT) is an overview of the federal income tax, mostly as it applies to individuals. It covers the fundamental principles of the federal income tax. It will address all the major issues, such as what gross income is, which expenditures are deductible, the appropriate taxable unit, the function of "basis," and the timing of income and deductions. Specific topics will include: employee fringe benefits, business deductions (e.g., travel), hobby losses, personal deductions (e.g., medical expenses and charitable contributions), the exclusions for gifts, bequests, and life insurance proceeds, taxation of the family, the tax treatment of loans, capital expenditures, methods of capital recovery (e.g., installment sales and depreciation), capital gains and losses, tax-free exchanges and rollovers, and tax accounting (e.g., the cash and accrual methods).

The instructor will emphasize use of both the Internal Revenue Code and the Treasury Regulations. 

Federal Income Tax covers basic principles of the federal income tax, including but not limited to the basic structure of the federal individual income tax. The primary objectives of the course are to familiarize you with those substantive principles; to introduce you to the format and content of the Internal Revenue Code, as well as related Treasury regulations, IRS guidance documents, and case law concerning basic federal income tax matters; and to give you experience working with a complicated statutory and regulatory scheme to resolve legal questions.

Textbooks:

J. Martin Burke & Michael K. Friel, Taxation of Individual Income (13th ed. 2023, Carolina Academic Press), ISBN: 978-1-530-2507-6        

Optional Statutory Supplement: Daniel J. Lathrope, Selected Federal Taxation Statutes and Regulations (2024 ed., West Academic Publishing), ISBN: 979-8-88786-000-8

Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.

Required Textbooks:

(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0

(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2023-2024 ed.)

Recommended Textbooks (Optional):

(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press) (Concepts and Insights Series)

(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic) (Concise Hornbook Series)

Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.

Required Textbooks:

(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0

(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2022-2023 ed.)

Recommended Textbooks (Optional):

(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press) (Concepts and Insights Series)

(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic) (Concise Hornbook Series)

This is a four-credit course. There are no prerequisites. No prior background in accounting, economics, math, or finance is needed or expected.

Federal Income Tax (FIT) is an overview of the federal income tax, mostly as it applies to individuals. It covers the fundamental principles of the federal income tax. It will address all the major issues, such as what gross income is, which expenditures are deductible, the appropriate taxable unit, the function of "basis," and the timing of income and deductions. Specific topics will include: employee fringe benefits, business deductions (e.g., travel), hobby losses, personal deductions (e.g., medical expenses and charitable contributions), the exclusions for gifts, bequests, and life insurance proceeds, taxation of the family, the tax treatment of loans, capital expenditures, methods of capital recovery (e.g., installment sales and depreciation), capital gains and losses, tax-free exchanges and rollovers, and tax accounting (e.g., the cash and accrual methods).

The instructor will emphasize use of both the Internal Revenue Code and the Treasury Regulations. 

This Federal Income Tax course uses a problem-based method to study core federal income tax doctrine, including the concepts of taxable income, adjustments to income, and when and to whom income is taxed. In addition, the course explores the policy choices presented by an income tax system, including equity, efficiency, administrability and political considerations. Federal Income Tax develops the universal lawyering skill of working with a statute-based body of law, in conjunction with administrative guidance and cases.  It asks how the income tax affects decisionmaking and interacts with the project of giving advice as a lawyer. The course is a gateway to more advanced tax offerings.

Federal Income Taxation (FIT) presents an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles and policies underlying the federal income tax and to convey the style and flavor of tax law thinking. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics that will be covered in reasonable depth include: the definition of gross income, including the specific inclusion and specific exclusion provisions, business and investment expense deductions, the exclusions for gifts, bequests, and recoveries for personal injuries, income attribution, the taxation of the family (including divorce taxation), the tax treatment of loans, capital expenditures, methods of capital recovery, capital gains and losses, tax-free exchanges, and various tax policy issues (including horizontal and vertical equity, economic efficiency, optimal tax theory, the tax expenditure concept, and a comparison of an income tax base with a cash flow consumption tax base). The grade for this course will be based entirely on a final, open book examination.

Required Textbooks:

(1) Joseph M. Dodge, J. Clifton Fleming, Jr., Francine J. Lipman & Robert J. Peroni, Federal Income Tax: Doctrine, Structure, and Policy (Carolina Academic Press 5th ed. 2019)—ISBN 978-1-5310-1311-0

(2) Federal Income Tax—Code & Regulations—Selected Sections, Robert J. Peroni, Coordinating Editor (Wolters Kluwer/CCH 2021-2022 ed.)—will be published in early to mid July 2021—new edition must be ordered

Recommended Textbooks (Optional):

(1) Marvin A. Chirelstein & Lawrence Zelenak, Federal Income Taxation (West Academic/Foundation Press 14th ed. 2018) (Concepts and Insights Series)—ISBN 9781640208247

(2) Donald B. Tobin & Samuel A. Donaldson, Principles of Federal Income Taxation (West Academic 8th ed. 2017) (Concise Hornbook Series)—ISBN 9780314287861

This is a four-credit course. There are no prerequisites. A prior background in accounting, economics, math, or finance is neither needed nor expected.

Federal Income Tax (FIT) is an overview of the federal income tax, mostly as it applies to individuals. The aim of the course is to present the fundamental principles underlying the federal income tax. As a survey, FIT will touch on all the major issues, such as what is gross income, what expenditures are deductible, what is the appropriate taxable unit, what is the function of "basis," and what is the appropriate timing of income and deductions. Specific topics will include: employee fringe benefits, business deductions (e.g., travel, entertainment, and education), hobby losses, personal deductions (e.g., medical expenses and charitable contributions), the exclusions for gifts, bequests, and life insurance proceeds, taxation of the family (including divorce), the tax treatment of loans, capital expenditures, methods of capital recovery (e.g., installment sales and depreciation methods), capital gains and losses, tax-free exchanges and rollovers, tax accounting (e.g., the cash and accrual methods), and the "tax benefit" rule.

The instructor will put great emphasis on using both the Internal Revenue Code and the Treasury Regulations. 

For any student pursuing a transactional practice or needing to learn the knowledge and skills necessary for actually doing finance deals and working with credit agreements, this is the class for you. After taking this course, students will understand the fundamental legal principles of finance transactions as well as the practical know-how of being an associate on a deal team. This class is designed for students interested in transactional groups at large law firms but any student wanting to understand transactional work would benefit from this course. There are many contract law, property law, commercial law and secured credit concepts that every young finance transactional attorney needs to know when starting their practice, and this class will arm you with what you must know from case law, statutory and scholarly readings and lectures. But in addition, this course will go beyond the fundamental legal knowledge that most classes only provide by doing a deep-dive into the actual documents that finance lawyers are routinely tasked with preparing and negotiating. So that with this class, each student will be ready to excel in the start of their careers by already having experience with the documents they will be responsible for preparing and reviewing.

This course provides a general framework – both theoretical and practical – to identify, analyze, and understand the tradeoffs that government regulators make when deciding financial and securities markets policy. You will develop the tools to understand the market failures and inefficiencies that lead to these choices, as well as their consequences on capital raising, investor welfare, securities trading, corporate governance, and financial stability.

At the end of the course you should understand how the legal and economic boundaries between investors, companies, and financial intermediaries give rise to incentives and behaviors that (1) fuel financial innovation, (2) lead to market abuses and fraud, (3) engender systemic risk, and (4) drive the need for continuous regulatory calibration to promote and maintain orderly and efficient markets. 

General topic areas are fixed, but the learning exercises and assignments will be guided by current market developments and practices among asset managers, securities dealers, banks, public corporations, and investment companies. Students are expected to carry a significant reading and writing load throughout the semester.

Topic areas covered     

• A brief history of financial markets
  • Evolution of banking, from Medici to Morgan; development of public securities markets; panics, crises, and the rise of capital market regulators
• The policy and politics of making rules
  • Congress, regulatory agencies, and the courts; identifying market failures; understanding the policy tradeoffs
• Securities fraud and misconduct
  • Insider trading, offering fraud, and financial misreporting; defining abusive market practices; detection methods and market surveillance
• Financial market stability
  • Causes and consequences of systemic risk; private market finance and shadow banking; international regulatory cooperation
• Technology disruptions and financial innovation
  • Approving new financial products; algorithmic trading and machine learning risks; FinTech and democratizing finance
• Social responsibility in securities regulation
  • Disclosure of ESG factors; pursuit of human rights; promoting diversity and inclusion

The class is designed for law students of all interests, including those who are undecided and those who are focused on a particular area such as litigation, public interest law, family law, regulatory work, criminal law, or business law. Financial Methods for Lawyers covers time value of money, expected value decision making, and investment in enterprises. It also covers the basic financial statement components: balance sheets, income statements and cash flow statements. The class is only available on a pass/fail basis. It is designated as a skills course. Students earn points toward a passing grade through online quizzes, Excel spreadsheet and other exercises, and regular attendance.

The class is designed for law students of all interests, including those who are undecided and those who are focused on a particular area such as litigation, public interest law, family law, regulatory work, criminal law, or business law.  Financial Methods for Lawyers covers time value of money, expected value decision making, and investment in enterprises.  It also covers the basic financial statement components: balance sheets, income statements, and cash flow statements.  The class is only available on a pass/fail basis.  It is designated as a skills course.  Students earn points toward a passing grade through online quizzes, Excel spreadsheet and other exercises, and regular attendance.

The class is designed for law students of all interests, including those who are undecided and those who are focused on a particular area such as litigation, public interest law, family law, regulatory work, criminal law, or business law. Financial Methods for Lawyers covers time value of money, expected value decision making, and investment in enterprises. It also covers the basic financial statement components: balance sheets, income statements and cash flow statements. The class is only available on a pass/fail basis. It is designated as a skills course. Students earn points toward a passing grade through online quizzes, Excel spreadsheet and other exercises, and regular attendance.