Legal scholars have long annotated cases by hand to summarize and learn about developments in jurisprudence. Dramatic recent improvements in the performance of large language models (LLMs) now provide a potential alternative. This Article demonstrates how to use LLMs to analyze legal documents....

A substantial academic literature considers how agencies should interpret statutes. But few studies have considered how agencies actually do interpret statutes, and none has empirically compared the methodologies of agencies and courts in practice. This Article conducts such a comparison, using...

Anti-abuse doctrines in tax law have traditionally been formulated as multi-factor tests that weigh the facts of the taxpayer's case but ignore the tax statute at issue. This approach has proven problematic: some judges import statutory considerations regardless, creating inconsistency and...

Every line of the Internal Revenue Code is continually vulnerable to revision or repeal. With each new session of Congress, rates may rise or fall, transactions may become taxable or tax-free, and incentive programs may be extended or repealed. The resulting uncertainty harms taxpayers, who find...

The era of big-government COVID relief is over. The initial pandemic relief legislation, followed by two years of Democratic control in Washington, seemed to herald the expansion and modernization of the U.S. safety net. But sustained reform proved elusive. Now that this lawmaking window of...

The purpose of this brief is to correct and respond to two arguments in Petitioner-Appellee Altera's petition for rehearing en banc and briefs of amici supporting the petition for rehearing. First, Treasury's regulation requiring cost sharing of stock-based compensation and the Ninth Circuit...

This paper examines the shortcomings of present tax and social welfare treatment of unskilled temporary workers in the United States. Uncovering systematic overtaxation and undersupport for migrant workers' financial stability, the paper then explores the effect of these policies on immigration...

The earned income tax credit and the child tax credit lift millions of families out of poverty each year, and are found to increase employment and improve health and education outcomes among recipients. Supporters of these programs also ascribe them with reducing average tax burdens for...

Property tax limits are state-level laws that place caps on local governments’ tax rates and revenue. These statutory limits, which put pressure on already strapped cities and counties in forty-six states, present an inexorable dilemma for local policymakers. On the one hand, they may cause...