Abstract

http://ssrn.com/abstract=2326526
 


 



Loving and Legitimacy: IRS Regulation of Tax Return Preparation


Steve R. Johnson


Florida State University - College of Law

September 16, 2013

Villanova Law Review, Vol. 60, Forthcoming
FSU College of Law, Public Law Research Paper No. 647

Abstract:     
The validity of regulations promulgated by the Department of Treasury is a principal battleground in contemporary federal taxation. So far, the clash has had two phases: establishment and implementation. Phase one entailed the destruction of the citadel of tax insularity, the bastion within which tax specialists thought to keep themselves safe from having to learn and apply general administrative law. In cases such as Swallows, Mannella, Lantz, Mayo, and the welter of cases culminating in Home Concrete, the old guard was defeated. It is now firmly established that tax, no less than other regulatory areas, is subject to the rules of administrative law. That proposition having been settled, we are now in phase two: implementation, the application of specific administrative law rules in particular tax contexts.

Number of Pages in PDF File: 71

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Date posted: September 16, 2013  

Suggested Citation

Johnson, Steve R., Loving and Legitimacy: IRS Regulation of Tax Return Preparation (September 16, 2013). Villanova Law Review, Vol. 60, Forthcoming; FSU College of Law, Public Law Research Paper No. 647. Available at SSRN: http://ssrn.com/abstract=2326526

Contact Information

Steve R. Johnson (Contact Author)
Florida State University - College of Law ( email )
425 W. Jefferson Street
Room R210
Tallahassee, FL 32306
United States
850-644-1777 (Phone)
HOME PAGE: http://www.law.fsu.edu/faculty/sjohnson.html
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