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"Slack" In The Administrative State And Its Implications For Governance: The Issue Of Accountability, David Markell
"Slack" In The Administrative State And Its Implications For Governance: The Issue Of Accountability, David Markell
Scholarly Publications
No abstract provided.
Further Thoughts On Kanter And Ballard, Steve R. Johnson
Further Thoughts On Kanter And Ballard, Steve R. Johnson
Scholarly Publications
On December 7, 2004, the Supreme Court will hear oral arguments in the consolidated Kanter and Ballard cases. The Tax Court had substantially upheld the IRS’s determinations of large deficiencies and fraud penalties against several taxpayers. The taxpayers argued in part that the Tax Court's application of its Rule 183 violated both due process and applicable statutes. I disagreed with those arguments then, and I continue to do so now. On appeal, the taxpayers' challenges to Rule 183 were rejected by the Fifth, Seventh, and Eleventh Circuits. The decisions of those circuits are sound and should be affirmed.
Both an …