This article concerns the history of automation in U.S. tax administration and the challenges automation presents to administering the laws consistent with democratic values. The most under-theorized aspect of tax administration is the expansion of automation and its impact on the current tax...

Governor Palin's 2006 and 2007 tax returns create several teaching opportunities for basic tax classes. This paper analyzes five substantive issues created by the returns and by a legal opinion letter written by Roger Olsen on some of the issues.The five issues are: (1) the proper treatment of...

CIC Services did not want to give the IRS certain information required by Notice 2016-66. It and another entity instead sued in federal district court, asking the court to: (1) declare Notice 2016-66 invalid and (2) permanently enjoin the Service from enforcing the Notice. The district court...

Like other federal courts, the Tax Court is very, very cautious about not overstepping its Congressionally-given bounds. However, the Tax Court also strives to allow taxpayers their day in Court. These two impulses --- the caution to stay within the statutory grants of power and the drive to...

This article examines the history and operation of the Taxpayer Advocate Service (TAS), a component of the Internal Revenue Service. Its thesis is that the TAS provides a necessary check on IRS operations, but not in the sense that the TAS reviews substantive decisions. Instead, the TAS serves...

The relationship of the APA to tax administration has been the subject of increasing scrutiny from scholars and courts. Some of this scrutiny has critiqued the long-held view of the Department of Treasury that tax regulations issued under the general grant of authority in I.R.C. § 7805(a) are...

In 2011 the Department of Treasury issued regulations that, for the first time, empowered the IRS to regulate the practice of preparing tax returns. Naturally, many tax return preparers were not happy about being regulated by the Feds. In 2013 a federal district judge nuked the regulations,...

Like fences, the statutes in subtitle F of the Tax Code define the operational area in which the IRS administers the tax laws. Statutory words - like pickets - place important boundaries on IRS action. Statutory silence - the spaces surrounding the words - can be just as important to understand...