INTRODUCTION “Distrust of the bureaucracy is surely one reason for the clamor for adversary proceedings in the United States.”[1] In a series of hearings in 1997 and 1998, Congress heard allegat...

Like fences, the statutes in subtitle F of the code define the operational area in which the IRS administers the tax laws. Statutory words — like pickets — place important boundaries on IRS action. St...

Introduction Taxation is shadow life. As our culture monetizes more and more life activities, the shadow grows. This Article looks at the potential tax issues arising from a new life activity: onli...

It is no accident that Justice Holmes penned those words in a tax case. Of all the corners in all the laws governing citizen interaction with government, tax laws contain some of the squarest. Today’s...

Good articles deserve to be read. Great ones deserve to be re-read. What Mortimer Caplin wrote some forty-five years ago deserves our renewed attention for the value it adds to the theory of tax admin...

I. INTRODUCTION One common issue facing those who create trusts is how to protect beneficiaries from creditors. One of the biggest, worst creditors out there is the Internal Revenue Service (IRS or...

In every era and area of law you find a never-ending battle between two groups of legal thinkers: formalists and functionalists. Each is connected to long-standing and honorable traditions in Anglo-Am...

I have a confession: I can't spell. Not that you can tell from my columns, where I successfully hide behind the spell-check function and the good efforts of Tax Analysts' editors. How bad am I? Well, ...

Bryan Camp and George H. Mahon Have you read the National Taxpayer Advocate's 2009 Annual Report? You know, the yearly 800-page compendium listing the 20 most serious taxpayer problems, recommendi...

The release of an opinion letter by attorney Roger M. Olsen dated September 30, 2008, has stirred up the pot once again about the accuracy of Sarah and Todd Palin's 2006 and 2007 tax returns. Not only...