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Full-Text Articles in Law
The Future Of Corporate Tax Reform: A Debate, Deborah A. Geier, Omni Y. Marian, David S. Miller, Adam H. Rosenzweig
The Future Of Corporate Tax Reform: A Debate, Deborah A. Geier, Omni Y. Marian, David S. Miller, Adam H. Rosenzweig
Law Faculty Articles and Essays
Professor Geier participated in a Lincoln-Douglas style debate, where the debaters were assigned different roles, so the opinions expressed were not necessarily their own. On the first point debated, Professor Geier was assigned to argue: The Affirmative: We Need to Tax Corporationsat the Entity Level. Others argued the negative: The United States Should Repeal the Corporate Income Tax. On the second point debated, Professor Geier argued the negative, that Dividend Exemption Is NOT the Best Method of Corporate/Shareholder Integration, and is in fact the worst method. On the third point, Professor Geier argued in the affirmative, that the corporate tax …
Section 7433'S Statute Of Limitations: How Courts Have Wrongly Turned A Taxpayer's Exclusive Sword Into The Irs's Shield Against Damages , Diana Leyden
Cleveland State Law Review
Congress expressly authorized taxpayers to bring a private cause of action against the United States for economic damages caused by “unauthorized collection.” Codified as section 7433 of the Internal Revenue Code, this statute provides taxpayers with the exclusive remedy for abuses by IRS employees in connection with the collection of taxes. ... Despite the importance of section 7433 to check government unauthorized tortious collection activity, federal courts have turned section 7433 into a shield against excessive or unsupported IRS collection action, rather than maintain it as the small, but important, sword that Congress intended to give taxpayer. This Article contributes …