Should we see major tax reform, taxpayers will clamor for guidance from Treasury and the Internal Revenue Service ('IRS') regarding new provisions, as they did after passage of the Tax Reform Act of 1986 ('1986 Act'). Indeed, the greater the degree of reform, the greater the need for guidance....

The Supreme Court waited until the last day of the 2009-10 Term to issue its pronouncement on business method patents, Bilski v. Kappos. It then came “not with a bang but a whimper.” Those who thought, based on statements in earlier Court opinions or the tenor of oral argument in Bilski,...