As former President George W. Bush said once, “the tax code is a complicated mess . . . [and] a million pages long.” The length and complexity of the Internal Revenue Code (Code) is largely the result of the U.S. government's rule-based approach to curtail tax abuse. Taxpayers, aided by...

This article examines the role of administrative adjudication in the United States constitutional system. It begins by noting that such adjudication fits uncomfortably within a system of divided powers. Administrative judges, including administrative law judges [ALJs] (who have the highest level...

Statutory interpretation is at the cutting edge of legal scholarship and, now, legislative activity. As legislatures have increasingly begun to perceive judges as activist meddlers, some legislatures have found a creative solution to the perceived control problem: statutory directives. Statutory...