Federal Taxation

Date

1988

Authors

Phelan, Marilyn E.

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Abstract

The Fifth Circuit issued decisions in twenty-seven cases involving federal taxation issues during the current survey period. Most of the cases involved tax procedure; few covered any unprecedented issues. Some of the tax protestor cases were unique in that the same taxpayers reappeared to echo their same specious deliberations. One tragic taxpayer appeared before the Fifth Circuit for the fourth time seeking redress from the alleged harsh investigative tactics of the IRS. The Fifth Circuit continued its tradition of applying a strict interpretation of the Code and regulations.

Description

Keywords

tax procedure, tax protester, IRS investigative tactics, strict construction

Citation

19 Tex. Tech L. Rev. 661 (1988)