Leigh Osofsky

University of North Carolina (UNC) at Chapel Hill

Associate Dean for Faculty Development and William D. Spry III Family Distinguished Professor of Law

102 Ridge Road

Chapel Hill, NC NC 27514

United States

  • University of North Carolina (UNC) at Chapel Hill

SCHOLARLY PAPERS

25

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6,424

TOTAL CITATIONS
Rank 43,322

SSRN RANKINGS

Top 43,322

in Total Papers Citations

20

Scholarly Papers (25)

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1.

Legislation and Comment: The Making of the § 199A Regulations

Emory Law Journal, Forthcoming, Boston College Law School Legal Studies Research Paper No. 493
Number of pages: 62 Posted: 09 Nov 2018 Last Revised: 27 Mar 2019
Shu-Yi Oei and Leigh Osofsky
Duke University School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 563 (106,214)
Citation 3

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199A, tax policy, taxation, legislation, regulations, administrative law, notice-and-comment, partnership taxation, agencies, tax reform

2.

Automated Legal Guidance

106 Cornell Law Review 179 (2020), UC Irvine School of Law Research Paper Forthcoming, UNC Legal Studies Research Paper
Number of pages: 67 Posted: 10 Mar 2020 Last Revised: 25 Mar 2021
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 509 (120,436)

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Artificial Intelligence, Automation, Tax Simplification, Taxpayer Communication, Transparency, IRS, Tax Compliance, Plain Language, Simplexity

3.

Simplexity: Plain Language and the Tax Law

66 Emory Law Journal 189 (2017), NYU Law and Economics Research Paper No. 16-17, University of Miami Legal Studies Research Paper No. 16-20
Number of pages: 77 Posted: 08 Apr 2016 Last Revised: 11 Apr 2017
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 448 (140,467)
Citation 8

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Tax Simplification, Taxpayer Communication, Tax Aggressiveness, Transparency, IRS, Tax Compliance, Plain Writing Act of 2010, Plain Language

4.

Unwinding the Ceiling Rule

Virginia Tax Review, 2014 Forthcoming
Number of pages: 36 Posted: 29 Mar 2014 Last Revised: 24 Jul 2014
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 384 (167,506)

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5.

Some Realism About Responsive Tax Administration

Tax Law Review, Vol. 66, 2012
Number of pages: 58 Posted: 11 Mar 2012 Last Revised: 01 Feb 2013
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 379 (169,941)
Citation 3

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Tax Policy, Responsive Regulation

6.

The Case for Categorical Nonenforcement

Tax Law Review, Vol. 69, 2015, University of Miami Legal Studies Research Paper No. 15-6
Number of pages: 61 Posted: 24 Oct 2014 Last Revised: 28 May 2015
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 375 (171,962)
Citation 1

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7.

The Inequity of Informal Guidance

75 Vanderbilt Law Review 1093 (2022), UC Irvine School of Law Research Paper No. 2021-44, UNC Legal Studies Research Paper
Number of pages: 66 Posted: 23 Aug 2021 Last Revised: 23 May 2022
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 371 (174,046)

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Internal Revenue Service, Tax Guidance, Tax Simplification, Tax Law, Two-tiered Legal System, Plain Language, Taxpayer Communication, Tax Compliance, Reliance, Administrative Guidance, Simplexity

8.

Democratizing Administrative Law

Duke Law Journal, forthcoming, 2024, UC Irvine School of Law Research Paper No. 2023-05, UNC Legal Studies Research Paper No. 4362529
Number of pages: 55 Posted: 23 Feb 2023 Last Revised: 18 Apr 2023
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 329 (198,454)

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Administrative Guidance, Reliance, Simplexity, Automated Legal Guidance, Administrative Procedure Act, Two-tiered Legal System, Agency Communications, Plain Language, Access to Justice

9.

Legal Calculators and the Tax System

15 Ohio St. Tech. L.J. __ (forthcoming, 2019), UNC Legal Studies Research Paper, UC Irvine School of Law Research Paper No. 2019-40
Number of pages: 17 Posted: 30 Jun 2019 Last Revised: 27 Feb 2020
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 301 (218,418)

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Artificial Intelligence, Automation, Tax Simplification, Taxpayer Communication, Transparency, IRS, Tax Compliance, Plain Language

10.

The Case Against Strategic Tax Law Uncertainty

Tax Law Review, Vol. 64, No. 4, 2011
Number of pages: 50 Posted: 11 Aug 2011 Last Revised: 13 Aug 2011
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 279 (236,577)
Citation 4

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tax compliance, uncertainty, risk, ambiguity, penalties

11.

Constituencies and Control in Statutory Drafting: Interviews with Government Tax Counsels

Iowa Law Review, Vol. 104, 2019 Forthcoming, Boston College Law School Legal Studies Research Paper No. 485
Number of pages: 76 Posted: 06 Jul 2018 Last Revised: 15 Aug 2018
Shu-Yi Oei and Leigh Osofsky
Duke University School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 278 (237,412)

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taxation, tax policy, statutory drafting, statutory interpretation, textualism, legislation, tax legislative process, Congress, congressional committees, qualitative research, interviews, empirical legal studies

12.

Who's Naughty and Who's Nice? Frictions, Screening, and Tax Law Design

Buffalo Law Review, Forthcoming
Number of pages: 62 Posted: 28 Mar 2013 Last Revised: 18 Dec 2013
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 261 (253,132)

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13.

Regulating by Example

Yale Journal on Regulation, Vol. 35, No. 1, 2017, University of Miami Legal Studies Research Paper No. 17-3, U of Texas Law, Public Law Research Paper No. 661
Number of pages: 52 Posted: 15 Feb 2017 Last Revised: 07 Nov 2017
Susan C. Morse and Leigh Osofsky
University of Texas at Austin - School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 250 (264,376)

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Regulation, Agencies, Law

14.

Concentrated Enforcement

Florida Tax Review, Vol. 16, No. 6, 2014
Number of pages: 67 Posted: 13 Dec 2013 Last Revised: 17 Oct 2014
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 230 (287,064)
Citation 1

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tax enforcement

15.

Automated Legal Guidance at Federal Agencies

Report for the Administrative Conference of the United States, May 27, 2022, UC Irvine School of Law Research Paper No. 2023-16, UNC Legal Studies Research Paper No. 4387719
Number of pages: 46 Posted: 17 Mar 2023 Last Revised: 24 Jul 2023
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 227 (290,625)

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Artificial Intelligence, Automation, Tax Simplification, Taxpayer Communication, Transparency, IRS, Tax Compliance, Plain Language, ACUS

16.

Automated Agencies

Minnesota Law Review, Vol. 104, 2023, UC Irvine School of Law Research Paper No. 2023-14
Number of pages: 78 Posted: 13 May 2023 Last Revised: 23 May 2023
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 195 (335,647)

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Artificial Intelligence, Chatbots, Automation, Agency Communication, Transparency, Plain Language, ACUS

17.

Implicit Legislative Bias: The Case of the Mortgage Interest Deduction

56 UC Davis Law Review 641 (2022), UNC Legal Studies Research Paper No. 4130609
Number of pages: 66 Posted: 17 Jun 2022 Last Revised: 13 Dec 2022
Leigh Osofsky and Kathleen DeLaney Thomas
University of North Carolina (UNC) at Chapel Hill and University of North Carolina School of Law
Downloads 194 (337,222)

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18.

The Surprising Significance of De Minimis Tax Rules

Washington and Lee Law Review, Vol. 78, No. 2, 2021, UNC Legal Studies Research Paper
Number of pages: 76 Posted: 14 Oct 2020 Last Revised: 23 Aug 2022
Leigh Osofsky and Kathleen DeLaney Thomas
University of North Carolina (UNC) at Chapel Hill and University of North Carolina School of Law
Downloads 170 (379,903)

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tax, legal rules, legislation, regulation

19.

Simplicity Lost

Pittsburgh Tax Review, 2023, UC Irvine School of Law Research Paper No. 2022-29, UNC Legal Studies Research Paper No. 4201658
Number of pages: 40 Posted: 08 Sep 2022 Last Revised: 24 Apr 2023
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 150 (427,231)

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Internal Revenue Service, Tax Simplification, Tax Law, Tax Complexity, Tax Compliance, Tax Compliance Burden, Internal Revenue Service Restructuring and Reform Act of 1998

20.

Agency Legislative Fixes

Iowa Law Review, Vol. 105, Forthcoming, UNC Legal Studies Research Paper
Number of pages: 63 Posted: 05 Sep 2019
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 148 (427,231)

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legislation, regulation, legislative drafting mistakes, congressional inaction, tax reform, ACA

21.

Democratic Accountability and Tax Enforcement

Harvard Journal on Legislation, forthcoming, 2024, UC Irvine School of Law Research Paper No. 2023-38, UNC Legal Studies Research Paper No. 4630550
Number of pages: 70 Posted: 29 Nov 2023
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 147 (429,603)

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Internal Revenue Service, Targeting, Antidiscrimination Law, Agency Communications, Democratic Accountability, Stanford Study, Audits, Racial Impact, Tax Enforcement

22.

Concentrated Enforcement in a Best-Case Tax Enforcement Regime

2014 IRS Research Bulletin
Number of pages: 14 Posted: 05 Jul 2014 Last Revised: 17 Oct 2014
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 125 (489,184)

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23.

Wellness and The Tax Law Georgia Law Review (forthcoming)

Number of pages: 58 Posted: 09 Sep 2024
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill
Downloads 75 (688,480)

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tax law, tax policy, medical expense, wellness

24.

Introduction to Automated Agencies: The Transformation of Government Guidance

(Cambridge University Press, forthcoming, 2025)
Number of pages: 10 Posted: 12 May 2025
Joshua D. Blank and Leigh Osofsky
University of California, Irvine School of Law and University of North Carolina (UNC) at Chapel Hill
Downloads 36 (995,295)

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Artificial Intelligence, Chatbots, Automation, Agency Communication, Transparency, Plain Language, ACUS

25.

Solving Section 734(b)

Tax Lawyer, Vol. 60, 2007
Posted: 20 Jun 2013
Leigh Osofsky
University of North Carolina (UNC) at Chapel Hill

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partnership tax

Other Papers (1)

Total Downloads: 66
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1.

How Agencies Communicate

Yale Journal on Regulation, Notice & Comment Blog
Number of pages: 21 Posted: 28 Mar 2018
Susan C. Morse, Leigh Osofsky, Elizabeth G. Porter, Kathryn A. Watts, Michael Herz, Andy Grewal, Nicholas R. Parrillo, Kevin M. Stack, Kristin E. Hickman, Christopher J. Walker and Aaron L. Nielson
University of Texas at Austin - School of Law, University of North Carolina (UNC) at Chapel Hill, University of Washington School of Law, University of Washington - School of Law, Yeshiva University - Benjamin N. Cardozo School of Law, University of Iowa - College of Law, Yale University - Law School, Vanderbilt University - Law School, University of Minnesota - Twin Cities - School of Law, University of Michigan Law School and Brigham Young University - J. Reuben Clark Law School
Downloads 66

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Administrative Law, Administrative Guidance, Communication, Deference, Regulations, Notice-and-Comment, Rulemaking, Examples