Leandra Lederman

Indiana University Maurer School of Law

William W. Oliver Professor of Tax Law

211 S. Indiana Avenue

Bloomington, IN 47405

United States

http://www.law.indiana.edu/people/lederman

  • Indiana University Maurer School of Law

    • Email
    • Tel: (812) 855-6149
    • Fax: (812) 855-0555
SCHOLARLY PAPERS

47

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Ideas:
“  In addition to the working papers here, I'm currently working on (1) 'Of Risks and Remedies: Best Practices in Tax Rulings Transparency', for which I received a 2019 Fulbright research grant, (2) the 4th edition of Understanding Corporate Taxation (with Michelle Kwon), which is in press with Carolina Academic Press; and an essay on valuation in the tax context.  ”

  • Indiana University Maurer School of Law

    • Email
    • Tel: (812) 855-6149
    • Fax: (812) 855-0555

Scholarly Papers (47)

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1.

'Stranger than Fiction': Taxing Virtual Worlds

New York University Law Review, Vol. 82, 2007, Indiana Legal Studies Research Paper No. 76
Number of pages: 54 Posted: 19 Mar 2007 Last Revised: 18 Oct 2015
Leandra Lederman
Indiana University Maurer School of Law
Downloads 1,914 (8,805)

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Virtual worlds, MMORPG, Second Life, World of Warcraft, taxation of barter, virtual property

2.

The Interplay between Norms and Enforcement in Tax Compliance

George Mason Law & Economics Research Paper No. 03-12; U of Texas, Public Law Research Paper No. 49
Number of pages: 62 Posted: 28 Mar 2003
Leandra Lederman
Indiana University Maurer School of Law
Downloads 930 (26,676)
Citation 13

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Taxation and Revenue, Tax Evasion, Fiscal Policies and Behavior of Economic Agents, Law and Economics, Tax Law, Legal Procedure

3.

The Fraud Triangle and Tax Evasion

Indiana Legal Studies Research Paper No. 398
Number of pages: 47 Posted: 28 Feb 2019 Last Revised: 23 Feb 2020
Leandra Lederman
Indiana University Maurer School of Law
Downloads 775 (34,479)

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fraud triangle, fraud diamond, tax evasion, tax fraud, white-collar crime, Donald Cressey, Edwin Sutherland, Svend Riemer, deterrence, fraud, opportunity to evade, tax noncompliance, tax compliance

4.

Tax Compliance and the Reformed IRS

George Mason Law & Economics Research Paper No. 03-13; U of Texas, Public Law Research Paper No. 50
Number of pages: 41 Posted: 28 Mar 2003
Leandra Lederman
Indiana University Maurer School of Law
Downloads 769 (34,835)
Citation 8

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Taxation Subsidies and Revenue, Tax Evasion, Fiscal Policies for Law and Economics, Tax Law, Legal Procedure

5.

The Use of Voluntary Disclosure Initiatives in the Battle Against Offshore Tax Evasion

Villanova Law Review, Vol. 57, 2012, Indiana Legal Studies Research Paper No. 200
Number of pages: 31 Posted: 31 Jan 2012 Last Revised: 11 Jul 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 657 (43,136)
Citation 4

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Tax compliance, tax evasion, voluntary disclosure, tax amnesty, FATCA, FBAR, UBS, offshore bank accounts

6.

W(h)ither Economic Substance?

Iowa Law Review, Vol. 95, p. 389, 2010, Indiana Legal Studies Research Paper No. 128
Number of pages: 57 Posted: 12 Mar 2009 Last Revised: 17 Jun 2014
Leandra Lederman
Indiana University Maurer School of Law
Downloads 474 (65,464)

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Business purpose, economic substance, tax shelter, Congressional intent, Gregory v. Helvering, Knetsch, Frank Lyon, sham transaction

7.

Statutory Speed Bumps: The Roles Third Parties Play in Tax Compliance

Stanford Law Review, Vol. 60, p. 695, 2007, Indiana Legal Studies Research Paper No. 78
Number of pages: 51 Posted: 12 Apr 2007 Last Revised: 28 Jun 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 464 (67,138)
Citation 1

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tax compliance, tax evasion, tax shelters, structural systems, third parties

8.

Reducing Information Gaps to Reduce the Tax Gap: When is Information Reporting Warranted?

Fordham Law Review Vol. 78, p. 1733, 2010, Indiana Legal Studies Research Paper No. 126
Number of pages: 28 Posted: 25 Feb 2009 Last Revised: 01 Jul 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 435 (72,642)

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Tax gap, tax compliance, tax evasion, information reporting, asymmetric information, income tax, gift tax, small businesses, eBay

9.

Which Cases Go to Trial?: An Empirical Study of Predictors of Failure to Settle

Case Western Reserve Law Review, Vol. 49, P. 315, 1999
Number of pages: 45 Posted: 08 May 2000
Leandra Lederman
Indiana University Maurer School of Law
Downloads 381 (84,872)
Citation 7

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10.

Do Attorneys Do Their Clients Justice? An Empirical Study of Lawyers' Effects on Tax Court Litigation Outcomes

Wake Forest Law Review, Vol. 41, p. 1235, 2006, Indiana Legal Studies Research Paper No. 49
Number of pages: 63 Posted: 07 May 2006 Last Revised: 26 Jun 2013
Leandra Lederman and Warren B. Hrung
Indiana University Maurer School of Law and Federal Reserve Bank of New York
Downloads 376 (86,190)
Citation 2

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lawyers, lawsuits, settlement, litigation, justice system, dispute resolution, judges, taxation, Tax Court, empirical study

11.

Tax Appeal: A Proposal to Make the United States Tax Court More Judicial

Washington University Law Review, Vol. 85, p. 1195, 2008, Indiana Legal Studies Research Paper No. 88
Number of pages: 55 Posted: 17 Oct 2007 Last Revised: 22 Jun 2008
Leandra Lederman
Indiana University Maurer School of Law
Downloads 368 (88,363)

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Transparency, accountability, federal courts, Tax Court, Article I courts, rulemaking, Special Trial Judges, Administrative Office of U.S. Courts, Rules Enabling Act

12.

Precedent Lost: Why Encourage Settlement, and Why Permit Non-Party Involvement in Settlements?

George Mason Law & Economics Research Paper No. 00-21, Indiana Legal Studies Research Paper No. 275
Number of pages: 50 Posted: 09 Aug 1999 Last Revised: 11 Dec 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 297 (112,139)
Citation 2

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13.

The Fight Over 'Fighting Regs' and Judicial Deference in Tax Litigation

Boston University Law Review, Vol. 92, 2012, Indiana Legal Studies Research Paper No. 186
Number of pages: 59 Posted: 19 Mar 2011 Last Revised: 11 Jul 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 278 (120,312)

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Chevron deference, Skidmore, Mayo Foundation, Brand X, Treasury regulation, Revenue Ruling, fighting regulation, pending litigation, Internal Revenue Service

14.

Does Enforcement Reduce Voluntary Tax Compliance?

2018 Brigham Young University Law Review 627, Indiana Legal Studies Research Paper No. 395
Number of pages: 75 Posted: 15 Aug 2018 Last Revised: 09 Jan 2019
Leandra Lederman
Indiana University Maurer School of Law
Downloads 274 (122,103)
Citation 2

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tax compliance, tax evasion, deterrence, enforcement, crowding out, bomb-crater effect, tax morale

15.

Enforcement as Substance in Tax Compliance

70 Washington & Lee L. Rev. 1679 (2013), San Diego Legal Studies Paper No. 13-117, Indiana Legal Studies Research Paper No. 236
Number of pages: 71 Posted: 07 May 2013 Last Revised: 04 Nov 2013
Leandra Lederman and Ted M. Sichelman
Indiana University Maurer School of Law and University of San Diego School of Law
Downloads 262 (128,023)

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tax compliance, tax enforcement, probabilistic enforcement, uncertainty

16.

The Federal Income Tax Consequences of the Bobble Supreme Phenomenon

Green Bag, Vol. 9, No. 2, p. 423, 2006, Indiana Legal Studies Research Paper No. 58
Number of pages: 8 Posted: 01 Sep 2006 Last Revised: 27 Jun 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 248 (135,400)

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tax, income, bobblehead, Supreme Court, humor, Green Bag

17.

EBay's Second Life: When Should Virtual Earnings Bear Real Taxes?

Yale Law Journal, Pocket Part, Vol. 118, p. 136, 2009, Indiana Legal Studies Research Paper No. 124
Number of pages: 7 Posted: 26 Feb 2009 Last Revised: 18 Oct 2015
Leandra Lederman
Indiana University Maurer School of Law
Downloads 238 (141,004)

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Virtual worlds, MMORPG, Second Life, World of Warcraft, eBay, PayPal, taxation

18.

The Entrepreneurship Effect: An Accidental Externality in the Federal Income Tax

Ohio State Law Journal Vol. 65, No. 6 (2004), George Mason Law & Economics Research Paper No. 04-36, Indiana Legal Studies Research Paper No. 6
Number of pages: 78 Posted: 11 Sep 2004 Last Revised: 26 Jun 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 238 (141,004)

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tax law, business tax, corporate finance, government policy

19.

What Do Courts Have to Do With It?: The Judiciary's Role in Making Federal Tax Law

Downloads 214 (156,114)
Citation 2

What Do Courts Have to Do With It?: The Judiciary's Role in Making Federal Tax Law

National Tax Journal, Vol. 65, No. 4, December 2012, Indiana Legal Studies Research Paper No. 216
Number of pages: 19 Posted: 02 Nov 2012 Last Revised: 12 Jul 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 187 (176,722)

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tax law, tax litigation, courts, Treasury, IRS

What Do Courts Have to Do with it?: The Judiciary's Role in Making Federal Tax Law

Revista Forumul Judecatorilor, No.1, 2013
Number of pages: 14 Posted: 21 May 2014
Leandra Lederman
Indiana University Maurer School of Law
Downloads 27 (539,841)

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federal tax law, federal tax litigation, taxpayers, general administrative law principles, Internal Revenue Service (IRS)

20.

IRS Reform: Politics as Usual?

7 Columbia Journal of Tax Law 36 (2016), Indiana Legal Studies Research Paper No. 337
Number of pages: 45 Posted: 15 Mar 2016 Last Revised: 22 Jun 2016
Leandra Lederman
Indiana University Maurer School of Law
Downloads 204 (163,235)

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IRS, Congress, reform, 501(c)(4), exempt organizations, nonprofits, Tea Party, Internal Revenue Service

21.

Ninth Circuit Supplemental Brief of Amici Curiae Reuven Avi-Yonah, Lily Batchelder, Joshua Blank, Noel Cunningham, Victor Fleischer, Ari Glogower, David Kamin, Mitchell Kane, Michael Knoll, Rebecca Kysar, Leandra Lederman, Zachary Liscow, Ruth Mason, Susan Morse, Daniel Shaviro, Stephen Shay, John Steines, David Super, Clinton Wallace, Bret Wells in Support of Respondent-Appellant Commissioner

Number of pages: 27 Posted: 15 Oct 2018
Susan C. Morse, Stephen E. Shay, Reuven S. Avi-Yonah, Lily L. Batchelder, Joshua D. Blank, Noel B. Cunningham, Victor Fleischer, Ari D. Glogower, David Kamin, Mitchell Kane, Michael S. Knoll, Rebecca M. Kysar, Leandra Lederman, Zachary D. Liscow, Ruth Mason, Daniel Shaviro, John P. Steines, David Super, Clint Wallace and Bret Wells
University of Texas at Austin - School of Law, Boston College Law School, University of Michigan Law School, New York University School of Law, University of California, Irvine School of Law, New York University Law School, UC-Irvine School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University School of Law, New York University (NYU), University of Pennsylvania Law School, Fordham University School of Law, Indiana University Maurer School of Law, Yale University - Law School, University of Virginia School of Law, New York University School of Law, New York University School of Law, Georgetown University Law Center, University of South Carolina School of Law and University of Houston Law Center
Downloads 199 (167,087)
Citation 1

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Altera, transfer pricing, Section 482, arbitrary and capricious, stock-based compensation

22.

Ninth Circuit Brief of Amici Curiae J. Richard Harvey, Leandra Lederman, Ruth Mason, Susan Morse, Stephen Shay and Bret Wells in Altera Corp. v. Commissioner, in Support of Respondent-Appellant Commissioner

Number of pages: 45 Posted: 08 Jul 2016 Last Revised: 02 Sep 2016
Susan C. Morse, J. Richard (Dick) Harvey, Leandra Lederman, Ruth Mason, Stephen E. Shay and Bret Wells
University of Texas at Austin - School of Law, Villanova University School of Law and Graduate Tax Program, Indiana University Maurer School of Law, University of Virginia School of Law, Boston College Law School and University of Houston Law Center
Downloads 196 (169,436)

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Cost-Sharing, Clear Reflection of Income, Comparability, Arm's Length Standard, Arbitrary, Capricious

23.

Equity and the Article I Court: Is the Tax Court's Exercise of Equitable Powers Constitutional?

Number of pages: 60 Posted: 16 Mar 2002
Leandra Lederman
Indiana University Maurer School of Law
Downloads 196 (169,436)
Citation 1

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24.

Information Matters in Tax Enforcement

2020 B.Y.U. L. Rev. __ (Forthcoming 2020)
Number of pages: 64 Posted: 31 Jan 2019 Last Revised: 02 Jan 2020
Leandra Lederman and Joseph Dugan
Indiana University Maurer School of Law and Indiana University Maurer School of Law
Downloads 181 (182,033)

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third-party reporting, information reporting, TPIR, tax compliance, tax enforcement, tax evasion, VATs, value-added taxes, small firms, large firms, firm compliance, firm honesty, corporate compliance, corporate honesty

25.

Of Taxpayer Rights, Wrongs, and a Proposed Remedy

Number of pages: 10 Posted: 09 Aug 2000
Leandra Lederman
Indiana University Maurer School of Law
Downloads 175 (187,494)

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26.

'Civil'Izing Tax Procedure: Applying General Federal Learning to Statutory Notices of Deficiency

U. C. Davis Law Review, Vol. 30, No. 1, 1996
Number of pages: 64 Posted: 08 May 2000
Leandra Lederman
Indiana University Maurer School of Law
Downloads 171 (191,254)
Citation 2

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27.

Addressing Imperfections in the Tax System: Procedural or Substantive Reform?

Michigan Law Review, Vol. 103, p. 1432, 2005 , IU Law-Bloomington Research Paper No. 23
Number of pages: 24 Posted: 08 Jun 2005 Last Revised: 13 Jun 2013
Leandra Lederman and Stephen W. Mazza
Indiana University Maurer School of Law and University of Kansas - School of Law
Downloads 163 (199,256)

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Taxation, tax compliance, IRS

28.

A Tisket, a Tasket: Basketing and Corporate Tax Shelters

Washington University Law Review, Vol. 88, p. 557, 2011, Indiana Legal Studies Research Paper No. 175
Number of pages: 53 Posted: 16 Jul 2010 Last Revised: 11 Jul 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 145 (219,725)

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Income taxation, corporate tax, tax shelters, basketing, passive activity losses, schedular taxation

29.

King v. Burwell: What Does It Portend for Chevron's Domain?

Pepperdine Law Review Online 72 (2015), Indiana Legal Studies Research Paper No. 326
Number of pages: 11 Posted: 24 Sep 2015 Last Revised: 12 Mar 2016
Leandra Lederman and Joseph Dugan
Indiana University Maurer School of Law and Indiana University Maurer School of Law
Downloads 137 (229,857)

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Chevron, deference, extraordinary cases, Affordable Care Act, Treasury regulations

30.

Transparency and Obfuscation in Tax Court Procedure

Number of pages: 6 Posted: 26 Aug 2004
Leandra Lederman
Indiana University Maurer School of Law
Downloads 134 (234,053)

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Tax law, tax procedure, tax policy, court procedure

31.

Report for the European Association of Tax Law Professors 2015 Congress: 'Tax Penalties as Instruments of Cooperative Tax Compliance Regimes'

(Annual Congress Milan 2015), IBFD AMSTERDAM (2016 Forthcoming) , Indiana Legal Studies Research Paper No. 320
Number of pages: 15 Posted: 29 Jul 2015 Last Revised: 10 Jun 2016
Leandra Lederman
Indiana University Maurer School of Law
Downloads 132 (236,795)

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tax compliance, tax evasion, tax penalties, additions to tax, responsive regulation

32.

Restructuring the U.S. Tax Court: A Reply to Stephanie Hoffer & Christopher Walker's 'The Death of Tax Court Exceptionalism'

99 Minnesota Law Review Headnotes 1 (2014), Indiana Legal Studies Research Paper No. 302
Number of pages: 29 Posted: 21 Sep 2014 Last Revised: 23 Dec 2014
Leandra Lederman
Indiana University Maurer School of Law
Downloads 122 (251,358)

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Tax Court, APA, Admistrative Procedure Act, Standard of Review, Scope of Review, Deference, Record Rule, Attorney General's Manual

33.

Surcharges and Penalties in Tax Law: United States

Annual Congress Milan 2015, IBFD Amsterdam (2016 Forthcoming), Indiana Legal Studies Research Paper No. 319, FSU College of Law, Public Law Research Paper No. 763, FSU College of Law, Law, Business & Economics Paper No. 15-19
Number of pages: 57 Posted: 28 Jul 2015 Last Revised: 10 Jun 2016
Stephen W. Mazza, Leandra Lederman and Steve R. Johnson
University of Kansas - School of Law, Indiana University Maurer School of Law and Florida State University - College of Law
Downloads 114 (264,011)

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penalties, interest, surcharges, additions to tax, tax controversies, tax litigation, tax procedure, tax evasion, tax compliance, tax crimes

34.

Late Returns Claiming Refunds: Negotiating the 'Fantastic Labyrinth'

Number of pages: 9 Posted: 10 Sep 2004
Leandra Lederman
Indiana University Maurer School of Law
Downloads 112 (267,405)

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35.

Taxpayer Rights in the Lurch: A Response to Professor Johnson

Number of pages: 11 Posted: 11 Sep 2004
Leandra Lederman
Indiana University Maurer School of Law
Downloads 109 (272,551)

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36.

Delinquent Returns and Credit-Elect Overpayments: A Procedural Tangle

Tax Notes, p. 831, August 2004, Indiana Legal Studies Research Paper No. 4
Number of pages: 13 Posted: 24 Aug 2004 Last Revised: 12 Jun 2013
Leandra Lederman
Indiana University Maurer School of Law
Downloads 109 (272,551)

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37.

Is the Taxpayer Bill of Rights Enforceable?

Indiana Legal Studies Research Paper No. 404
Number of pages: 25 Posted: 26 Apr 2019
Leandra Lederman
Indiana University Maurer School of Law
Downloads 107 (276,057)
Citation 2

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TBOR, Taxpayer Bill of Rights, Facebook, IRS appeal, Appeals Office, NTA, National Taxpayer Advocate

38.

Deficient Statutory Notices and the Burdens of Proof: A Reply to Mr. Newton

Number of pages: 8 Posted: 10 Sep 2004
Leandra Lederman
Indiana University Maurer School of Law
Downloads 99 (291,099)

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39.

When the Bough Breaks: The U.S. Tax Court's Branch Difficulties

34 ABA Tax Section NewsQuarterly 10 (Winter 2015), Indiana Legal Studies Research Paper No. 311
Number of pages: 3 Posted: 01 Feb 2015 Last Revised: 31 Mar 2015
Leandra Lederman
Indiana University Maurer School of Law
Downloads 96 (296,924)
Citation 1

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Tax Court, separation of powers, judicial branch, legislative branch, execultive branch, Article I

40.

The IRS, Politics, and Income Inequality

Tax Notes, Vol. 150, No. 11, 2016, Indiana Legal Studies Research Paper No. 341
Number of pages: 7 Posted: 19 Mar 2016 Last Revised: 07 Jun 2016
Leandra Lederman
Indiana University Maurer School of Law
Downloads 93 (303,033)

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IRS, income inequality, progressive taxation, Congress, Internal Revenue Service

41.

(Un)Appealing Deference to the Tax Court

Duke Law Journal, Vol. 63, No. 8, 2014, Indiana Legal Studies Research Paper No. 285
Number of pages: 62 Posted: 12 May 2014 Last Revised: 14 May 2014
Leandra Lederman
Indiana University Maurer School of Law
Downloads 93 (303,033)

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Tax Court, appellate review, judicial deference, tax controversies, tax procedure, tax litigation, Dobson rule, Justice Jackson

42.

Ninth Circuit Brief of Law Academics and Professors as Amici Curiae in Opposition to the Petition for Rehearing En Banc in Altera v. Commissioner

Number of pages: 34 Posted: 18 Sep 2019
Leandra Lederman, Susan C. Morse, Stephen E. Shay, Clint Wallace, Reuven S. Avi-Yonah, Lily L. Batchelder, Jeremy Bearer-Friend, Joshua D. Blank, Leslie Book, Bryan Camp, Noel B. Cunningham, Victor Fleischer, J. Clifton Fleming, Keith Fogg, David Gamage, Ari D. Glogower, Mitchell Kane, Ariel Jurow Kleiman, Edward D. Kleinbard, Rebecca M. Kysar, Zachary D. Liscow, Ruth Mason, Omri Y. Marian, Robert J. Peroni, Darien Shanske, Daniel Shaviro, John P. Steines, Bret Wells and Eric M. Zolt
Indiana University Maurer School of Law, University of Texas at Austin - School of Law, Boston College Law School, University of South Carolina School of Law, University of Michigan Law School, New York University School of Law, George Washington University Law School, University of California, Irvine School of Law, Villanova University School of Law, Texas Tech University School of Law, New York University Law School, UC-Irvine School of Law, Brigham Young University - J. Reuben Clark Law School, Tax Clinic at Legal Services Center of Harvard Law School, Indiana University Maurer School of Law, Ohio State University (OSU) - Michael E. Moritz College of Law, New York University (NYU), University of San Diego School of Law, University of Southern California Gould School of Law, Fordham University School of Law, Yale University - Law School, University of Virginia School of Law, University of California, Irvine School of Law, University of Texas at Austin - School of Law, University of California, Davis - School of Law, New York University School of Law, New York University School of Law, University of Houston Law Center and University of California, Los Angeles (UCLA) - School of Law
Downloads 84 (322,936)

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Altera, transfer pricing, arm's length, Tax Court, en banc, Section 482, stock-based compensation

43.

More Mayo Please? Temporary Regulations after Mayo Foundation V. United States

Number of pages: 2 Posted: 07 Dec 2011
Leandra Lederman and Stephen W. Mazza
Indiana University Maurer School of Law and University of Kansas - School of Law
Downloads 55 (405,008)

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44.

Increasing Transparency in the U.S. Tax Court

Law 360 (Dec. 4, 2018)
Number of pages: 7 Posted: 27 Jan 2019
Leandra Lederman
Indiana University Maurer School of Law
Downloads 36 (479,433)
Citation 1

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Tax Court, Transparency, Accountability, Court Records, PACER

45.

Tax Court S Cases: Does the 'S' Stand for Secret?

79 Tax Notes 257 (Apr. 13, 1998)
Number of pages: 2 Posted: 19 Jun 2016
Leandra Lederman
Indiana University Maurer School of Law
Downloads 26 (530,695)

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Tax Court, small tax cases, S cases, transparency, court opinions

46.

Are There Procedural Deficiencies in Tax Fraud Cases? A Reply to Professor Schoenfeld

35 Ind. L. Rev. 143 (2001)
Number of pages: 31 Posted: 13 Jul 2016
Leandra Lederman
Indiana University Maurer School of Law
Downloads 18 (580,753)

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Notice of Deficiency, Tax Court, IRS, Deficiency Determination, Tax Deficiency

47.

U.S. Supreme Court Brief of Amica Curiae Leandra Lederman in Ballard v. Commissioner, in Support of Petitioners

BRIEF AS AMICA CURIAE IN BALLARD V. COMMISSIONER, 544 U.S. 40 (2005) (Aug. 2, 2004), Indiana Legal Studies Research Paper
Number of pages: 35 Posted: 06 Nov 2018
Leandra Lederman
Indiana University Maurer School of Law
Downloads 11 (627,888)
Citation 2

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U.S. Tax Court, transparency, rulemaking, tax litigation, Special Trial Judges, Rule 183