Levin College of Law
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Steven J. Willis

Professor of Law

CV

SSRN

bepress (SelectedWorks)

Phone:
(352) 273-0680

Expertise

Accounting  • Bill of Rights  • Charitable Entities and Charitable Giving  • Family Law  • Federalism  • Finance  • States Rights  • Tax Law  • Tenth Amendment  • 

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 (inactive) 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 and is developing The Tax Law of Charities.

Professor Willis is the co-author of two traditional casebooks: The Tax Law of Charities (Carolina Academic Press 2021) and Tax Accounting (2012 Lexis). He has also authored two treatises, Accounting For Lawyers (West 2024) and Finance For Lawyers (West 2021). His scholarship has been cited in multiple federal courts as well as in many law reviews and books. He has taught law in the Netherlands, Poland, and South Africa.

Professor Willis is the faculty advisor for numerous student organizations including the Christian Legal Society (which provides multiple student support groups), the Federalist Society Chapter (recognized nationally), and the Law School Republicans. For many years he coached Tax Moot Court (which won numerous national and international awards), and he advised VITA (which annually provided tax preparation for over 700 low-income clients).

Education

LL.M., (Taxation), New York University (1980)
J.D., Louisiana 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
  • Timing Issues in Taxation
  • Finance for Lawyers
  • Accounting for Lawyers

Publications

Books

  • Accounting for Lawyers (West 2024).
  • Finance for Lawyers (West 2021).
  • The Tax Law of Charities (Carolina Academic Press 4th ed., 2021) (with David Brennen, Beverly I Moran,  & Daryll K. Jones)
  • The Tax Law of Charities (2014) (with Jones, Brennen, & Moran) (LEXIS) (3d Ed. 2014)
  • Accounting and Taxation in Light of the New EU Strategy (after IAS/IFRD) (Chapter representing the U.S.) published by the University of Turin (2016)
  • Statutory Supplement to The Tax Law of Charities  (2004)  (with Jones, Brennan, & Moran) (West Publishing Company) (2d Ed. 2008)
  • Tax Accounting (with Manning & Lang) (LEXIS, 2006)

Articles

  • Taxing Torts Today and Tomorrow, 92 Tenn. L. Rev. ___ (forthcoming 2025).
  • A Game Theory View of Family Law: Planning for a 500% Family Tax, 18 FIU L. REV. 151 (2023).
  • 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)

University of Florida Levin College of Law
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PO Box 117620
Gainesville, FL 32611
(352) 273-0804
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The Florida Constitutional Law Endowment in memory of Justice Ben F. Overton was created by Judge Karen Miller in 2013. This fund supports lectures and presentations by Justices of the Florida Supreme Court at the Fredric G. Levin College of Law.

HISTORY

Justice Overton, who earned his B.S. in 1951 and his Juris Doctor in 1952 from the University of Florida, was the first merit appointment to the Florida Supreme Court. Throughout his career he was active in legal education and served as an Adjunct Professor at the Levin College of Law through December 2012, the month of his death. Although he resided at Oak Hammock at the University of Florida, a continuing care retirement community developed in cooperation with UF, he also considered the Florida Supreme Court “home.” Among the high points of his later years was hosting Justices of the Florida Supreme Court in Gainesville and taking his class to Tallahassee to hear oral arguments at the Florida Supreme Court.
Judge Miller, who earned her B.S. cum laude from New York University in 1974 and her Juris Doctor from New York Law School in 1977, served as Chief Administrative Law Judge of the New York City Department of Consumer Affairs, New York City’s business regulatory agency, before she retired to Oak Hammock at the University of Florida. Having accompanied Justice Overton on his excursions to Tallahassee and joined him in welcoming guests to Oak Hammock at the University of Florida, she created the endowment in memory of Justice Overton to ensure that the Levin College of Law continues to have the funding necessary to continue and enhance the interaction between its students and the Florida Supreme Court.

 

Judge Miller remembered the event that motivated the endowment.

 

Prior to a dinner at the home of Dean Robert Jerry and Lisa Jerry shortly after Justice Overton’s death, Justice Barbara Pariente and I were discussing a suitable memorial. Justice Pariente, who had been Justice Overton’s colleague on the Florida Supreme Court and who understood the importance to him of the interaction between his students and the Court, suggested the outline of what has become the Overton lectures. Dean Jerry, who has since retired, as has Dean Emeritus Jon Mills, who assumed responsibility for implementing the Overton lectures, were very supportive from the beginning. Since Dean Mills’ retirement, Professor Timothy McClendon, who assisted both Justice Overton and Dean Mills teaching Florida Constitutional Law and who co-authored the recent Florida Constitutional Law casebook, has continued the Overton lectures with the support of Interim Dean Merritt McAlister and CGR director, Professor Danaya Wright.

Justice Overton was a devoted jurist, educator, and ethical leader of the Florida legal profession. The Overton Lecture Series brings Florida Supreme Court Justices to the University of Florida, Levin College of Law, and serves to introduce students to the inner workings of the Court. CGR and the students of the College of Law extend our deepest gratitude to Judge Karen Miller for making the Overton Lectures possible in perpetuity.

You can watch an interview for the Florida Historical Society by Mary Adkins, professor emeritus of the UF Levin College of Law, with Justice Overton here.

Justice Overton was also interviewed for the Samuel Proctor Oral History Project and a transcript of his interview is available at the Smathers Library, and here.
Justice Overton sat on the Constitution Revision Commission of 1977-78 that proposed a right to privacy in the Florida Constitution. Although it failed as part of the Constitution Revision Commission recommendations, it passed in 1980 when proposed by the legislature. The bill was co-sponsored by our very own Jon Mills. The privacy provision prevailed by greater than 60%. Justice Overton then wrote a concurrence in a critical reproductive rights case in 1989 affirming that the privacy provision of the Florida Constitution included the right to obtain an abortion. That decision was overruled in Planned Parenthood of SW and Central Florida v. Florida. You can read about the role of Justice Overton, Jon Mills – director emeritus of CGR, and the history of the 1989 case here.