Dr. Jenkins' History



D. R. Jenkins, "The ESOP Flush," Journal of Pension Planning & Compliance,

            44(1), Spring 2018, forthcoming.


D. R. Jenkins, "Structuring the Closely Held Enterprise for Dynamic Growth,"

            Journal of Taxation of Investments, 35(3) Spring 2018, pp. 33-62.


D. R. Jenkins, "Social Choice Theory Implications for Management Company

            ESOP Structures," Employee Benefit Plan Review, 72(5), February 2018, pp.



D. R. Jenkins, "A Note on the Noncorporate Lessor Activity Conclusive

            Presumption," Journal of Taxation, 128(2), February 2018, pp. 36-38.


D. R. Jenkins, "Why Section 179(b)(3)(A)'s Business Income Limitation Does Not

            Apply to Partnerships or S Corporations," The Contemporary Tax Journal,

            7(1), Article 3, Winter 2018, pp. 1-31.





D. R. Jenkins, "State Non-Rebate Refund Errors: Due Process, Procedure, and Practice," Journal of State Taxation, 35(4), Fall 2017, pp. 19-28, 43-44.


D. R. Jenkins, “Contract Harvesting and Treasury’s Farming Business Definition Executive Fiat,” Drake Journal of Agricultural Law, 22(2), Summer 2017, pp. 55-76.


D. R. Jenkins, “Untrapping the Self-Rental Trap,” D. R. Jenkins, “Defensive Tax Return Disclosures,” The Real Estate Finance Journal (Thomson Reuters), Summer 2017, pp. 44-50.


D. R. Jenkins, “Defensive Tax Return Disclosures,” The Real Estate Finance Journal (Thomson Reuters), Summer 2017, pp. 32-43.


D. R. Jenkins, “Treasury’s Passive Activity Interest Abuse of Power,” Journal of Taxation of Investments, 34(3), Spring 2017, pp. 51-69.


D. R. Jenkins, “Management Company ESOP Structures, the Transfer for Value Doctrine,

           and the 3-Year Pull-Back Rule, “ Employee Benefit Plan Review, 71(9), March/April

           2017, pp. 11-17.


D. R. Jenkins, “How to Write a Tax Advisory Opinion Letter,” Real Estate Finance Journal 

           (Thomson Reuters), Winter/Spring 2017, pp. 48-66.





Algorithm Management Consultants LLC is formed.


D. R. Jenkins, "Changing ERISA's Disqualified Person Criterion," Employee Benefit Plan

            Review, 70(9), March 2016, pp. 14-18.


D. R. Jenkins, "Arizona's Transaction Privilege Tax Executive Fiat," Journal of State

            Taxation, 34(2), Spring 2016, pp. 33-39.


D. R. Jenkins, "Got Your Assets Covered?," Journal of Pension Planning & Compliance,

            42(2), Summer 2016, pp. 1-25.


D. R. Jenkins, “The Problem with Cherwenka,” Pratt’s Journal of Bankruptcy Law, 12(5),

            July/August 2016, pp. 245-67.


D. R. Jenkins, "Resolving the Passive Custodian Paradox," Journal of Pension Planning &

            Compliance, 42(3), Fall 2016, pp.21-44.


D. R. Jenkins, “Retirement Plan Nontraditional Asset Valuation Appraiser Liability

            Exposures,” Employee Relations Law Journal, 42(3), Winter 2016, pp. 33-43.


D. R. Jenkins, “Section 409(p)’s Economically Substantive Succession Planning Policy

            Implications,” Employee Benefit Plan Review, 71(4), October 2016, pp. 24-28.


D. R. Jenkins, “Management Company ESOP Structures and the Insurable Interest

            Doctrine,” Employee Benefit Plan Review, 71(5), November 2016, pp. 5-12.


D. R. Jenkins, “Policy Compliant Retirement Plan Real Estate Financing Structures,” The

            Real Estate Finance Journal (Thomson Reuters), Fall/Winter 2016, pp. 58-90.


D. R. Jenkins, “Section 469 Activity and Participation Conclusive Presumptions,” Journal

           of Taxation, 125(4), October 2016, pp. 168-179.


D. R. Jenkins, “Section 469(c)(7) Procedure, Practice, and Regulatory Implications,” 

           Journal of Taxation, 125(6), December 2016, pp. 270-278.





D. R. Jenkins, "Section 4975(e)(2)(G) Management and Investment Risk

           Diversification Standards" is published in The Journal of Taxation of

           Invesments32(4), Summer 2015, pp. 59-77.


D. R. Jenkins, "The Internal Revenue Service Acknolwedges Involvement in Jenkins

           Related Judicial Martial Law Activities," IRS Office of Appeals Briefs and

           Decisions, August 2015.


D. R. Jenkins, "Simple Substantial Economic Effect Regulatory Compliance," EA

           Journal, 33(5), September/Octover 2015, pp.14-19.


D. R. Jenkins, "Management and Investment Risk Diversification Indices," Employee

          Benefit Plan Review, 70(4), October 2015, pp. 26-35.


D. R. Jenkins, "Building Prohibited Transaction Chinese Walls for Retirement Plan

          Investment Structures," Journal of Taxation, 123(5), November 2015, pp. 218-30.


D. R. Jenkins, "Problematic Self-Directed Retirment Plan Activities," Journal of Pension

          Planning & Compliance, 41(4), Winter 2016, pp. 65-88.


Algorithm LLC becomes an IRS approved continuing education provider.


Algorithm LLC becomes an IRS approved e-file provider.




Algorithm LLC is formed to continue the consulting tradition described in this History section.


D. R. Jenkins, "Why Section 530 of the Revenue Act of 1978 Applies to the States,"

             The Contemporary Tax Journal, 4(1), Fall 2014, pp. 9-20.



D. R. Jenkins, "Ordered Conflict Resolution," Éthique et économique/Ethics and

             Economics, 7 (1), 2010.



The first treatise providing empirical evidence of the judiciary's use of informal information signals is published: Judicial Martial Law, 657 pp.



The first paper to provide a theoretical basis for the Kaplan and Norton Balanced Scorecard is published.  


D. R. Jenkins, "Ordered Model Processes, Reference Declaration and the Economic

            Organization: Implications for a Balanced Scorecard Contextual

            Framework," Éthique et économique/Ethics and Economics, 5 (1), 2007.


The Balanced Scorecard is a widely acclaimed managerial accounting strategy formulation tool.



Ordered Conflict Resolution tenets are founded in the Antithetical-Primary Population General Impossibility Theorem (APPGIT). Ordered Conflict Resolution underscores (individual: societal) well-being transitivity and competent social policy-making. Theretobefore, the field of economics promulgated empirical research in search of a theory to dethrone Professor Arrow's 1951 impossibility theorem.




Financing infrastructures are designed to bring long-term public and private financing to countries lacking the necessary investment grade sovereign credit rating. Traditionally, no risk inside a sovereign is able to have a credit rating higher than the sovereign itself. Syndicated surety arrangements endowed with AAA reinsurance treaties served to bridge the sovereign risk limitation.



Congress modifies Section 351 of the tax code to eliminate the issuance of debt securities in tax-free exchanges of appreciated property to a corporation. Savvy tax planners know the single remaining strategy to effect tax-free exchanges of appreciated property to a corporation for stock and debt securities lies in Section 368(a)(1)(E) recapitalizations.



D. W. Vickrey, T. W. Foster III, and D. R. Jenkins, "The Incremental Information

              Content of the Annual Report," Accounting and Business Research, Spring

              1986, pp. 15-21.



Twenty business plans are authored in this period, including reviewed financial forecasts by an international accounting firm, that lead to in excess of $100 million of capital funding in the United States, Belgium, and Switzerland.



The book, Post-TEFRA Holding Company Strategies, explains the TEFRA-surviving succession planning strategy, Bottom Freezing.


D. W. Vickrey, T. W. Foster III, and D. R. Jenkins, "Additional Evidence on the

              Incremental Information Content of the 10-K," The Journal of Business,

              Finance and Accounting, Spring 1983, pp. 57-66.




The first graduate school course blending operations research decision-making models and estate and income tax planning strategies is developed and taught at the University of Arizona in Tucson.


President Reagan's second tax act, the Tax Equities and Fiscal Responsibilities Act of 1982, among other things, attacked the strategy of using newly formed parent holding corporations in the closely-held business setting as a means of effecting value-freezing succession planning techniques.


Predicated on a Supreme Court decision entered at the time of TEFRA's enactment, the TEFRA-surviving succession planning strategy, Bottom Freezing, is developed and emerges as a strong and vibrant succession planning tool.



President Reagan's first tax act, the Economic Recovery Tax Act of 1981, radically changes depreciation in the tax code. Section 167(a), the provision that enabled Discounted Sum of the Years Rents, is effectively replaced by Accelerated Cost Recovery System depreciation methodologies.



Succession planning seminars are presented in McDonald's Corporation regional franchisee meetings throughout the nation. This occurred at a time when the first generation of McDonald's franchisees planned to pass franchise interests to their children.


Sound succession planning strategies involving balanced amounts of stock and securities (bonds, notes, etc.), private annuities, and irrevocable trusts have the concomitant effect of eliminating or minimizing estate tax exposure while reducing income taxes through bracket averaging and the conversion of ordinary income cash-flow streams into return-of-basis and capital gains cash-flow streams.




Succession planning using a Fortran-coded decision-making model is the first of its kind throughout the nation. The model enables decision analysis of estate and income tax planning trade-offs.


The depreciation method Discounted Sum of the Years Rents is first developed and survives audit by the Internal Revenue Service. The economically sound depreciation method, based on time value of money notions, depreciates at rates faster than the Double-Declining Balance method.

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