Now showing items 1-10 of 45
Theory and Practice in Tax Administration
(Virginia Tax ReviewVirginia Tax Review, 2009)
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 ...
What Good Is the National Taxpayer Advocate?
(Tax Notes, 2010-03)
Part A of this article explains how important changes in tax administration since World War II have created the need for an office such as TAS. Part B will examine the structure of TAS operations since its reorganization ...
Proceduralist Reflections on Home Mortgage Foreclosures
(Tax Notes, 2007)
In tax law and theory, procedure gets short shrift. Yet sometimes, procedure makes all the difference. That seems to me to be particularly true regarding the recent publicity over the tax consequences of foreclosures on ...
Avoiding the Ex Post Facto Slippery Slope of Deer Park
(American Bankruptcy Institute Law Review, 1995)
This Article contends that bankruptcy courts had no power to order the Internal Revenue Service (IRS) to allocate funds to trust fund taxes or non-trust fund taxes by granting designation orders ex post facto. It argues ...
The Play’s the Thing: A Theory of Taxing Virtual Worlds
Taxation is shadow life. As our culture monetizes more and more life activities, the shadow grows. This article looks at the potential tax issues arising from a new life activity: online role-playing games in virtual worlds. ...
Why the Supreme Court of New York Is Not the Supreme Court of New York
(Haverford Journal, 2006)
This paper explores both the decision to abolish the New York Court for the Correction of Error and Trial of Impeachment (CCE) and the debate on how to reform the Supreme Court which resulted in the decision to still leave ...
Retroactivity of Treasury Regulations: Paths to Finding Abuse of Discretion
(Virginia Tax Review, 1988)
Professor Camp, then a student, analyzes ways in which courts may find abuse of discretion under § 7805(b) of the Internal Revenue Code, which creates a presumption of retroactivity of any ruling by the IRS.
(Tax Notes, 2005)
Professor Camp argues that the collection due process of Tax Administration is the wrong solution to an erroneous problem and then proceeds to give the correct answer to the actual problem.
Presumptions and Tax Return Preparer Fraud
(Tax Notes, 2008)
Just because the IRS has the legal authority to act, argues Professor Camp, does not mean that it should. The Tax Court's decision in Allen v. Commissioner, where the court agreed to let the IRS use old language for a new ...
Unhappy Marriage of Law and Equity in Joint Return Liability
(Tax Notes, 2005)
This column discusses what happens when Congress attempts to smooth out the sharp corners of the tax code with notions of equity, but does so with an inadequate understanding of, or appreciation for, the problems of tax ...