Now showing items 31-40 of 41
Is the Individual Mandate Really Mandatory?
(Tax Notes, 2012-06-25)
This article examines the tax collection process to see how the IRS might enforce the individual mandate under the healthcare reform law. It concludes that resistant taxpayers can generally be forced to pay the tax penalty ...
A History of Tax Regulation Prior to the Administrative Procedure Act
The relationship of the APA to tax administration has been the subject of increasing scrutiny from scholars and courts. Some of this scrutiny has critiqued the long-held view of the Department of Treasury that tax regulations ...
"Loving" Return Preparer Regulation
In 2011, the Department of Treasury issued regulations that, for the most time, empowered the IRS to regulate the practice of preparing tax returns. Naturally, many tax return prepares were not happy about being regulated ...
Failure of Collection Due Process, Part 2: Why It Adds No Value
(Tax Notes, 2004)
Professor Camp continues his argument of why the CDP provisions of §§ 6330 & 6320 are a failure.
Evil That Men Do Lives After Them . . .
(Tax Notes, 2004)
Professor Camp examines the the Senate Finance Committee’s investigation of IRS abuse in 1998.
Professor Camp’s treatise chapter focuses on the procedure for a refund claim and limitations for refund claims, amounts that can be recovered, and refund suits.
Form Over Substance in Fifth Circuit Tax Cases
(Texas Tech Law Review, 2002)
As with most litigation, tax litigation comes down to substance and procedure. By "substance" Professor Camp means controversy over the proper amount of tax. By "procedure" he means litigation over the proper process of ...
Tax Return Preparer Fraud and the Assessment Limitation Period
(Tax Notes, 2007)
Professor Camp’s thesis is that the section 6501(a) assessment limitation period represents a very strong public policy choice in favor of closure, far stronger than a typical statute of limitation. Accordingly, he believes ...
Function of Forms
(Tax Notes, 2006)
Interpreting Statutory Silence
(Tax Notes, 2010-08)
Like fences, the statutes in subtitle F of the Tax Code define the operational area in which the IRS administers the tax laws. Statutory words - like pickets - place important boundaries on IRS action. Statutory silence - ...