66 Am. U. L. Rev. 1323 (2017)

*Professor, Southern Illinois University School of Law.  Member, American Law Institute.  Partner and Associate, Husch Blackwell Sanders LLP (1985–2005).  Washington University School of Law, Adjunct Professor, Graduate Tax Program (1996–2000).  New York University School of Law, LL.M. (Executive) (2013); Washington University School of Law, LL.M. in Intellectual Property (2003); Washington University School of Law, LL.M. in Taxation (1997); St. Louis University School of Law, J.D. (1985).  Professor Drennan practiced law full-time for twenty years in the areas of tax-exempt organizations, charitable giving, tax, estate planning, and business law.  Special thanks to Jennifer Davies, Class of 2018, for her excellent editorial and research assistance.