George H. Mahon Professor of Law, Texas Tech University School of Law

4 years
The Failure of Adversarial Process in the Administrative State

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...

5 years
Interpreting Statutory Silence

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...

5 years
The Play’s the Thing: A Theory of Taxing Virtual Worlds

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...

5 years
The Unhappy Marriage of Law and Equity in Joint Return Liability

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...

5 years
Theory and Practice in Tax Administration

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...

5 years
Protecting Trust Assets From the Federal Tax Lien

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...

6 years
The Never-Ending Battle

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...

6 years
Tax Return Preparer Fraud and the Assessment Limitation Period

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, ...

7 years
What Good Is The National Taxpayer Advocate?

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...

7 years
A Brief Analysis of Governor Palin’s Tax Returns for 2006 and 2007

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...

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