Levin College of Law

Steven J. Willis

University Term Professor
Professor of Law

Phone:
(352) 273-0680

About

Professor Willis’s legal experience includes positions as a trial law clerk for Judge Davis (of the Fifth Circuit Court of Appeals), and as a tax/transactional lawyer with Phelps Dunbar in New Orleans. He is licensed to practice in both Florida and Louisiana and is a CPA in Louisiana. He has written numerous federal appellate briefs in tax cases, as well as cases involving religious freedom. He is an active writer and scholar. He has been a leader in developing distance learning courses with current offerings in Finance For Lawyers and Accounting for Lawyers. He is the faculty advisor for numerous student organizations including Tax Moot Court (which has won many national and international awards), VITA (which annually provides tax preparation for over 800 low-income clients), the Federalist Society Chapter (recognized nationally), and the Christian Legal Society (which provides multiple student support groups).

Professor Willis is the co-author of two traditional books: The Tax Law of Charities (Carolina Academic Press 2021) and Tax Accounting (2012 Lexis). He has also authored electronic books for Distance Learning: Accounting for Lawyers, Finance for Lawyers, and a Financial and Accounting Dictionary. His scholarship has been cited in multiple federal courts as well as many law reviews and books. He has taught law in the Netherlands, Poland, and South Africa.

Education

LL.M., (Taxation), New York University (1980)
J.D., Lousiana State University, cum laude, Order of the Coif (1977)
B.S., (Accounting) Louisiana State University, cum laude (1974)

Teaching and Scholarship

Tax Exempt Organizations; Tax Timing; Accounting & Finance for Lawyers; Income Tax; Partnership Tax; Marriage Dissolution: Support and Property Division

Courses

Tax Exempt Organizations - LAW 7633
  • Study of exemption from federal income tax accorded to a variety of public and private organizations, and tax treatment of contributions to such organizations; public policies underlying exemption from tax and deductibility of contributions.
Timing Issues in Taxation - LAW 7604
  • To learn the fundamentals of timing issues in federal income taxation in order to help prepare students, as tax lawyers, to recognize, appreciate and advise on the tax consequences of timing aspects of transactions and events encountered in tax practice. The course has three main parts: Accounting Methods, Time Value of Money and Error Correction.

Publications

Books

  • Finance for Lawyers (West 2021)
  • The Tax Law of Charities (Carolina Academic Press 2021) (with David Brennen, Beverly I Moran,  & Daryll K. Jones)
  • The Tax Law of Charities (2014) (with Jones, Brennen, & Moran) (LEXIS) (3d Ed. 2014)
  • Teacher’s Manual for The Tax Law of Charities (2014) (with Jones, Brennen, & Moran) (LEXIS) (3d Ed. 2014)
  • Statutory Supplement to The Tax Law of Chraities
  • The Tax Law of Charities (2004) (1100 pages) (with Jones, Brennan, & Moran) (West Publishing Company) (2d Ed. 2007)
  • Statutory Supplement to The Tax Law of Charities (2004) (with Jones, Brennan, & Moran) (West Publishing Company) (2d Ed. 2008)
  • Teacher’s Manual for The Tax Law of Charities (2004) (with Jones, Brennan, & Moran) (West Publishing Company) (2d Ed. 2008)
  • Tax Accounting (with Manning & Lang) (LEXIS, 2006)
  • Teacher’s Manual for Tax Accounting (with Manning & Lang) (LEXIS, 2006)

Articles

  • Naked Stripping for Alimony and Child-Support Tax Benefits, 73 Tax Law. 861 (2020)
  • How a Spouse Can Profit by Paying Partner’s Principal, 49 N.M. L. Rev. 283 (2019) [SSRN]
  • Affordable Care Act Fails for Lack of Uniformity, 27 U. Fla. J. Law. Publ. Pol’y 81 (2016) (with Hans Tanzler IV) [SSRN]
  • Transferee Liability: Fifth Circuit Opportunity to Stop Injustice, 142 Tax Notes 309 (2014) (with Brooks and Rivera)
  • Corporations, Taxes, and Religion: The Hobby Lobby and Conestoga Contraceptive Cases, 66 S.C. L. Rev. 1 (2013) [SSRN]
  • No Healthcare Penalty? No Problem: No Due Process, 38 Am. J.L. & Med. 516 (2012) (with Nakku Chun) [SSRN]
  • Of Constitutional De-Capitation and Health Care, 128 Tax Notes, 129 (2010) (with Chung) [SSRN]
  • People in Glass Houses, 113 Tax Notes 477 (2006) [SSRN]
  • Family Law Economics, Child Support, and Alimony: Ruminations on Income, Part I , 78 Fla. Bar J. 34 (May 2004) [SSRN]
  • Family Law Economics, Child Support, and Alimony: Ruminations on Income, Part II , 78 Fla. Bar J. 34 (June 2004) [SSRN]
  • Show Me the Numbers…Please, 93 Tax Notes 1321 (2001) [SSRN]
  • It’s Time For Schlude to Go, 93 Tax Notes 127 (2001) [SSRN]
  • Equitable Recoupment: More Pitfalls for the Unwary, 75 Tax Notes 361 (1998) [SSRN]
  • Offensive v. Defensive Equitable Recoupment, 74 Tax Notes 207 (1997) [SSRN]
  • Erroneous Deductions and the Tax Benefit Rule, 68 Tax Notes 1479 (1995) [SSRN]
  • Albertson’s: A Little Less Emotion, Please, 64 Tax Notes 961 (1994) [SSRN]
  • Leave Albertson’s Alone, 63 Tax Notes 1481 (1994) [SSRN]
  • The Option Aspect of Nonrecourse Loans, 54 Tax Notes 441 (1992) [SSRN]
  • Correction of Errors Via Equitable Recoupment and Tax Mitigation: Some People Still Do Not Understand, 52 Tax Notes 1421 (1991) [SSRN]
  • A Different View of the Tax Benefit Rule: A Unified Theory of Error Correction, 42 Fla. L. Rev. 575 (1991) [SSRN]
  • Masks, Magic and Games: The Use of Tax Law As a Policy Tool, 4 Am. J. Tax Pol’y 41 (1985) [SSRN]
  • Some Limits of Equitable Recoupment, Tax Mitigation, and Res Judicata: Reflections Prompted by Chertkof v. United States, 38 Tax Lawyer 625 (1985) [SSRN]
  • I.R.C. Section 274(b) and Duberstein Resurface: The Emperor Still Has No Clothes, 25 Ariz. L. Rev. 907 (1983) (with Hawley) [SSRN]
  • Of [Im]Permissible Illogic and Section 1031, 34 Fla. L. Rev. 72 (1982) [SSRN]
  • Carry-over Basis Provisions of the Tax Reform Act of 1976: Section 1023, 31 Tax Lawyer 191 (1977) (with Landry) [SSRN]
  • Corporations, Fiduciaries, and Conflicts of Interest, 37 La. L. Rev. 809 (1976) [SSRN]

Appellate Briefs (primary author)

  • Amicus Curiae, Brief with FreedomX Foundation, Sebelius v. Hobby Lobby; Conestoga Wood Specialties Corp v. Sebelius, Nos. 13-354; 13-356, Supreme Court of the United States (2014)
  • Amicus Curiae, Brief with Tax Foundation, United States v. Marshall, No. 12- 20804, U.S. Court of Appeals for the Fifth Circuit (2013)
  • Amicus Curiae, Susan Seven Sky v. Holder, No. 11-5047, Court of Appeals for the D. C. Circuit (2011)
  • Amicus Curiae, Brief with Catholic Vote, United States v. State of Florida, No. 11- 398, Supreme Court of the United States (2011)
  • Amicus Curiae, Letter Brief with Pacific Legal Foundation, Commonwealth of Virginia v. Sebelius, No. 11-1057, U.S. Court of Appeals for the Fourth Circuit (2011)
  • Amicus Curiae, Thomas More Law Cntr. v. Obama, No. 10-2388, U. S. Court of Appeals for the Sixth Circuit (2010)