Federal Taxation

Examines the Fifth Circuit’s contemporary federal taxation cases, in which the court largely reaffirmed its own precedent and followed the majority of other circuits on these issues. One exception involves the case of United States v. Barrett, in which the court reversed its earlier position on the impact of IRS disclosure of embarrassing taxpayer return information on the enforcement of an IRS summons. During the survey period, the court strengthened both the ability of a taxpayer to collect attorney’s fees from the government, and the court’s ability to sanction tax protesters.