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Full-Text Articles in Law
The Doctrine Of Judicial Estoppel, Steve R. Johnson
The Doctrine Of Judicial Estoppel, Steve R. Johnson
Scholarly Publications
The doctrine of judicial estoppel is not on some lawyers’ radar screens. That’s regrettable. Not anticipating application of the rule, a person may make a claim that can hurt him or her in the long run. Or, unaware of the rule, a party may fail to assert a potentially successful defense. Or, having only a very general awareness of the rule, an attorney may miss subtleties or forum variations that are the difference between winning and losing.
This article has three parts. Part I describes the doctrine of judicial estoppel, emphasizing its purposes. Part II explores the recent judicial estoppel …
The 1998 Act And The Resources Link Between Tax Compliance And Tax Simplification, Steve R. Johnson
The 1998 Act And The Resources Link Between Tax Compliance And Tax Simplification, Steve R. Johnson
Scholarly Publications
Tax compliance sometimes is thought of as purely a matter of administration. But there are important connections between substance and procedure.' Both affect compliance. This article explores how simplification of the substantive tax law can improve compliance. The particular emphasis is on how simplification can liberate human and material resources for the IRS without which otherwise well conceived efforts to improve compliance are likely ultimately to fail.
Tax Reality Bites, Jeffrey H. Kahn
Secondary Liability For Federal Trust Fund Taxes, Steve R. Johnson
Secondary Liability For Federal Trust Fund Taxes, Steve R. Johnson
Scholarly Publications
When collection of unpaid taxes cannot be effected from the person primarily liable for them, the Internal Revenue Code creates for the IRS a number of mechanisms for collection from secondary parties. To satisfy the requirements of fairness and due process, secondary liability is imposed only when the party has some nexus to the liability, that is, when that person's actions helped create the liability or frustrated its collection from the primary taxpayer.
This article discusses l.R.C. § 6672, one of the most widely used and important of the secondary liability mechanisms in tax. There are numerous § 6672 assessments …
The Canon That Tax Penalties Should Be Strictly Construed, Steve R. Johnson
The Canon That Tax Penalties Should Be Strictly Construed, Steve R. Johnson
Scholarly Publications
No abstract provided.