The subject of taxpayer rights is receiving increasing attention worldwide. Tax scholars, practitioners, and administrators are grappling with the challenges of delivering on the promise of taxpayer rights, the benefits of success, and the price of failure. Nevertheless, a fundamental question...

Although fields of law ordinarily comprise both rules and standards, and foundational tax scholars such as Professors Surrey, Warren, and Bittker understood the importance of standards in tax law, many tax scholars and professionals have come to regard federal tax law as “the paradigmatic...

In this article we tackle a fundamental problem in tax law: the resistance of the core concept of “income” to a coherent definition. It has long been recognized that there is a substantial gap between the formal definition of income adopted in 1955 by the Supreme Court in Commissioner v....

In this article I argue that when an "occupation" becomes a "profession," pressures build for its members to act unethically precisely because of what it has come to mean to be a profession. My focus will be on the profession of law because legal practice has particular qualities that make these...

This is not just another tax reform piece. Although the tax system changed at midnight on New Year's eve, 2017, in the flurry of activity to understand the new legislation and its effects, almost no attention has been paid to analyzing whether the income tax system has been transformed in any...

The ABA Tax Section Teaching Taxation Committee hosted a panel on promoting diversity in tax, as part of the ABA Tax Section Fall 2021 Meeting. This document is the panel organizer’s and presenters’ slides for Promoting Diversity, Equity, and Inclusion in Tax: Ideas and Resources to Mentor...

In this article Professors McMahon and Abreu examine data on changes in the distribution of income and show that those changes increasingly reflect a winner-take-all pattern in which economic rewards are increasingly skewed toward those at the top 1% of the income distribution. These changes in...

Across the globe, the subject of immigration is politicized and polarizing. In the United States, the unauthorized immigrant population, I assert, is the result of immigration policies ill-suited to address economic and humanitarian realities. Specifically, undocumented immigrant workers yield...

Disregarded entities, single member limited liability companies whose separate legal existence is ignored for all purposes under the Internal Revenue Code, were created by the Check-the-Box regulations. Their creation was a logical consequence of the objective of those regulations, which was to...