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Full-Text Articles in Law
When Helpers Hurt: Protecting Taxpayers From Preparers, Michelle L. Drumbl
When Helpers Hurt: Protecting Taxpayers From Preparers, Michelle L. Drumbl
Michelle L. Drumbl
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Words Of Wisdom From The Founding Fathers: Why The Internal Revenue Service Should Let Churches Be, Sophia Benavides
Words Of Wisdom From The Founding Fathers: Why The Internal Revenue Service Should Let Churches Be, Sophia Benavides
Journal of the National Association of Administrative Law Judiciary
Part I of this comment will explore the foundations of the First Amendment, as the Constitution is a framework on which the United States continues to rest. An examination of the events contributing and leading to the drafting of the Constitution will illuminate the rationale behind the tenets put forth by the Founding Fathers. More specifically, this comment will devote emphasis to the Founding Fathers’ objectives regarding the state in relation to religion. This emphasis will provide insight into the perspective of the Founders at the time of drafting the First Amendment. Furthermore, this section will illustrate how the separation …
Redefining “Peril”—Abating The Interest On A Tax Deficiency For Good Faith Reliance On Irs Publications, Brady Cox
Pepperdine Law Review
Many taxpayers rely on guidance materials the IRS provides in order to comprehend the United States Tax Code and pay an accurate tax. However, many, if not all, of these taxpayers would likely be startled to learn that their reliance on these IRS guidance materials is perilous. That is, that reliance upon these guidance materials will not support a taxpayer’s tax treatment decisions if the IRS decides that the decisions were incorrect under substantive law. However, because the courts have not decisively concluded which financial consequences a taxpayer faces or escapes by relying on informal IRS guidance, “peril” remains undefined. …
The Rise And Fall Of Chevron In Tax: From The Early Days To King And Beyond, Steve R. Johnson
The Rise And Fall Of Chevron In Tax: From The Early Days To King And Beyond, Steve R. Johnson
Pepperdine Law Review
Chevron is receding in tax, not because of any resurgence of tax exceptionalism but because it is receding everywhere. The case will continue to be cited by courts and masticated by commentators, but the unresolved – indeed worsening — conceptual, definitional, and practical incongruities of its doctrine rob it of operational force. King, which the Supreme Court conspicuously chose to resolve without “help” from Chevron, is another mile-marker on Chevron’s downward road. This article maps that road.