New audit rules targeting sophisticated tax partnerships unnecessarily burden small, unsophisticated taxpayers. This is a familiar narrative in partnership tax. This time, the story takes place in the rules that prescribe the process by which the IRS audits and collects tax from partnerships and...

Traditionally, statutory regulation was viewed as the primary mechanism for achieving environmental and social change. Its uniform system and top down implementation was expected to engineer social and environmental change at every location. However, this vision never constituted an entirely...

Increasingly, Congress allows the president to determine tax consequences with the stroke of a pen. For example, if the president declares a major disaster under the Stafford Act, affected taxpayers are allowed a deduction for net personal casualty losses. This Article surveys instances of...