This article presents a critique of the economic substance doctrine and suggests an alternative. The economic substance doctrine under certain circumstances overrides the technical provisions of the Internal Revenue Code. Congress recently incorporated into the Code a version similar to the...

When examining a corporate taxpayer, the IRS often seeks special accounting documents called tax accrual workpapers. These workpapers often contain privileged documents, but the IRS does not care. It believes it is entitled to the documents despite that the work product doctrine protects the...

How does the IRS's ruling that both parties to an exchange of services are subject to income tax apply in the dating context? When meeting, dating, living together, or potentially raising a child together, single people provide services for each other. Most are unaware that potential tax...

This article analyzes issues related to the Tax Court's constitutional status. Although the issue has been debated for decades, recent litigation has revived the issue. In Battat v. Commissioner, the primary issue before Tax Court was whether the President's limited removal power over tax judges...

Tax protesters offer uncommonly silly arguments in support of their positions -- so silly, in fact, that courts commonly refuse to address them, lest those arguments be given any credence. Yet the wave of tax protester arguments has not ebbed, and tax protesters continue to challenge, for...