Steve R. Johnson

Florida State University - College of Law

425 W. Jefferson Street

Room R210

Tallahassee, FL 32306

United States

http://www.law.fsu.edu/faculty/sjohnson.html

SCHOLARLY PAPERS

96

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7,521

CITATIONS
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13

Scholarly Papers (96)

1.

Reflections on Seminole Rock: The Past, Present, and Future of Deference to Agency Regulatory Interpretations

Yale Journal of Regulation, Notice & Comment Blog, Washington University in St. Louis Legal Studies Research Paper No. 2847668, Minnesota Legal Studies Research Paper No. 16-41, Virginia Public Law and Legal Theory Research Paper No. 2017-38
Number of pages: 77 Posted: 07 Oct 2016 Last Revised: 10 Aug 2017
Brigham Young University - J. Reuben Clark Law School, University of Washington - School of Law, University of Pittsburgh - School of Law, University of Virginia - School of Law, George Washington University Law School, Independent, Cato Institute, Ohio State University (OSU) - Michael E. Moritz College of Law, Vanderbilt University - Law School, University of Iowa - College of Law, Florida State University - College of Law, University of North Carolina School of Law, Case Western Reserve University School of Law, New York University School of Law, Munger, Tolles & Olson, LLP, Harvard Law School, Harvard Law School, Washington University in St. Louis - School of Law, affiliation not provided to SSRN, Stanford University - Constitutional Law Center, Utah Supreme Court, Columbia University - Law School, Lewis & Clark Law School, University of Minnesota - Twin Cities - School of Law, Notre Dame Law School, George Mason University - Antonin Scalia Law School and Yale University, Law School
Downloads 1,032 (20,453)

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Administrative Agencies, Seminole Rock, Auer, What Is New in Administrative Law, Deference, Chevron

2.
Downloads 851 ( 27,095)
Citation 1

When General Statutes and Specific Statutes Conflict

State Tax Notes, Vol. 57, p. 113, 2010, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-35
Number of pages: 5 Posted: 31 Aug 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 824 (27,918)
Citation 1

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legislation, statutory construction, state and local taxes

When General Statutes and Specific Statutes Conflict

State Tax Notes, p. 113, July 2010, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 27 (493,207)

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3.

An IRS Duty of Consistency: The Failure of Common Law Making and a Proposed Legislative Solution

Tennessee Law Review, Vol. 77, No. 3, Spring 2010, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-07
Number of pages: 88 Posted: 12 Sep 2009 Last Revised: 29 Mar 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 325 (91,713)

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4.

The Taxpayer's Duty of Consistency

Tax Law Review, Vol. 46, p. 538- 1990-1991
Number of pages: 46 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 220 (137,852)

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5.

Loving and Legitimacy: IRS Regulation of Tax Return Preparation

59 Villanova Law Review 515, FSU College of Law, Public Law Research Paper No. 647
Number of pages: 48 Posted: 16 Sep 2013 Last Revised: 18 Feb 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 188 (159,714)

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6.

Preserving Fairness in Tax Administration in the Mayo Era

Virginia Tax Review, Vol. 32, No. 1, Summer 2012, FSU College of Law, Public Law Research Paper No. 592
Number of pages: 74 Posted: 19 Apr 2012
Steve R. Johnson
Florida State University - College of Law
Downloads 181 (165,260)

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7.
Downloads 170 (174,748)

Substantial Compliance

State Tax Notes, Vol. 53, No. 169, 2009
Number of pages: 12 Posted: 18 Sep 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 109 (249,588)

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Substantial Compliance

State Tax Notes, p. 169, July 20, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 5 Posted: 29 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 61 (356,461)

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8.

How Far Does Circular 230 Exceed Treasury's Statutory Authority?

146 Tax Notes 221, 2015, FSU College of Law, Public Law Research Paper No. 737
Number of pages: 20 Posted: 22 Feb 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 165 (179,233)
Citation 1

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9.

Auer/Seminole Rock Deference in the Tax Court

Pittsburgh Tax Review, Vol. 11, 2013, Forthcoming, FSU College of Law, Public Law Research Paper No. 630
Number of pages: 55 Posted: 04 Apr 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 150 (194,269)

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10.

Uniformity Clause Limitations on State Taxes

ABA Section of Taxation Newsquarterly, Vol. 27, p. 12, 2008, FSU College of Law, Public Law Research Paper
Number of pages: 2 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 147 (197,447)

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11.

A Modest Proposal to Improve Tax Compliance: Curbing Penalty-Protection Opinions

Florida Tax Review, Forthcoming
Number of pages: 89 Posted: 16 Oct 2008 Last Revised: 18 Jul 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 145 (199,725)

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Tax compliance

12.

The Selective Enforcement Defense in Civil and Criminal Tax Cases

ABA Section of Taxation Newsquarterly, Winter 2008, FSU College of Law, Public Law Research Paper
Number of pages: 15 Posted: 27 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 131 (216,766)

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13.
Downloads 117 (236,013)
Citation 1

Substance and Form in State Taxation

State Tax Notes, Vol. 50, p. 239, 2008
Number of pages: 8 Posted: 03 Jun 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 89 (286,329)

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Substance and Form in State Taxation

State Tax Notes, p. 239, 2008, FSU College of Law, Public Law Research Paper No. 564
Number of pages: 4 Posted: 01 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 28 (487,574)

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14.

The 1998 Act and the Resources Link between Tax Compliance and Tax Simplification

Kansas Law Review, Vol. 51, 2003, FSU College of Law, Public Law Research Paper
Number of pages: 52 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 113 (241,962)

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15.
Downloads 109 (248,276)

The Two Kinds of Legislative Intent

State Tax Notes, Vol. 51, p. 1045, 2009
Number of pages: 8 Posted: 03 Jun 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 90 (284,260)

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state and local tax statutes interpretation

The Two Kinds of Legislative Intent

State Tax Notes, p. 1045, March 2009, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 19 (543,117)

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16.

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 107 (251,483)

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

17.

Reforming Federal Tax Litigation: An Agenda

Florida State University Law Review, Vol. 41 (Forthcoming), FSU College of Law, Public Law Research Paper No. 631
Number of pages: 103 Posted: 04 Apr 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 107 (251,483)

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18.

Retroactive Tax Legislation

81 State Tax Notes 529, FSU College of Law, Public Law Research Paper No. 812
Number of pages: 8 Posted: 21 Sep 2016
Steve R. Johnson
Florida State University - College of Law
Downloads 106 (253,178)

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19.

Mayo and the Future of Tax Regulation

Tax Notes, Vol. 130, No. 13, March 2011, FSU College of Law, Public Law Research Paper No. 523
Number of pages: 11 Posted: 15 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 91 (280,049)

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20.

State Tax Malpractice Actions: Statutes of Limitations

State Tax Notes, Vol. 51, p. 119, 2009
Number of pages: 11 Posted: 03 Jun 2009 Last Revised: 06 Aug 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 90 (282,008)

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21.
Downloads 90 (282,008)

Supertext and Consistent Meaning

State Tax Notes, Vol. 52, 2009
Number of pages: 11 Posted: 30 May 2009 Last Revised: 24 Jun 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 63 (350,551)

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statutory interpretation, supertext, consistent meaning

Supertext and Consistent Meaning

State Tax Notes, p. 675, May 25, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 27 (493,207)

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22.

Pro-Taxpayer Interpretation of State and Local Tax Laws

State Tax Notes, Vol. 51, p. 441, 2009, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 09-07
Number of pages: 9 Posted: 03 Jun 2009 Last Revised: 02 Jul 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 87 (288,118)

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tax litigation, state taxes, local taxes, statutory interpretation

The Reenactment and Inaction Doctrines in State Tax Litigation

State Tax Notes, Vol. 50, p. 661, 2008
Number of pages: 10 Posted: 03 Jun 2009 Last Revised: 06 Aug 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 64 (347,620)

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canons of statutory interpretations, state and local taxes

The Reenactment and Inaction Doctrines in State Tax Litigation

State Tax Notes, p. 661, December 8, 2008, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 23 (517,392)

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Legislative Rhetoric, or How to Oppose Anything

State Tax Notes, Vol. 53, No. 461, 2009
Number of pages: 11 Posted: 18 Sep 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 47 (403,341)

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Legislative Rhetoric, or How to Oppose Anything

State Tax Notes, p. 461, August 17, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 5 Posted: 29 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 38 (439,412)

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25.

The Use and Abuse of the 'Plain Meaning' Doctrine

StateTax Notes, Vol. 49, p. 831, 2008
Number of pages: 11 Posted: 03 Jun 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 84 (294,468)

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26.

Fog, Fairness, and the Federal Fisc: Tenancy-by-The-Entireties Interests and the Federal Tax Lien

Missouri Law Review, Vol. 60, 1995, FSU College of Law, Public Law Research Paper
Number of pages: 50 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 81 (301,025)

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27.

What Davis Means for Constitutional and Statutory Interpretation

State Tax Notes, Vol. 48, p. 877, 2008, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 09-14
Number of pages: 33 Posted: 30 May 2009 Last Revised: 01 Aug 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 79 (305,537)

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Commerce Clause, constitutional interpretation, statutory interpretation, state tax exemptions

Equitable Tolling in State and Local Tax Cases

State Tax Notes, Vol. 52, No. 917, 2009
Number of pages: 11 Posted: 18 Sep 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 58 (365,686)

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Equitable Tolling in State and Local Tax Cases

State Tax Notes, p. 917, June 15, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 29 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 20 (536,638)

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29.

Using Administrative Law to Challenge IRS Determinations

88 The Florida Bar Journal 81 (2014), FSU College of Law, Public Law Research Paper No. 736
Number of pages: 3 Posted: 22 Feb 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 77 (310,180)

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The Work Product Doctrine and Tax Accrual Workpapers

Tax Notes, Vol. 124, No. 155, 2009
Number of pages: 42 Posted: 18 Sep 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 63 (350,551)

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The Work Product Doctrine and Tax Accrual Workpapers

Tax Notes, Vol. 124, p. 155, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 7 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 14 (575,755)

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31.

Taxes, Free Expression, and Adult Entertainment

State Tax Notes, Vol. 62, No. 2, 2011, FSU College of Law, Public Law Research Paper No. 556
Number of pages: 4 Posted: 13 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 71 (324,738)

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32.

The 'Absurd Results' Doctrine in State and Local Tax Cases

State Tax Notes, Vol. 54, p. 195, 2009, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-19
Number of pages: 5 Posted: 17 Aug 2010 Last Revised: 18 Aug 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 71 (324,738)

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absurd results, absurdity, taxation, statutory interpretation, textualism, state and local taxes

33.

Statutes Requiring 'Plain Meaning' Interpretation

State Tax Notes, Vol. 53, No. 763, 2009
Number of pages: 14 Posted: 18 Sep 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 70 (327,316)

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34.

Chevron Deference to State Tax Agencies

State Tax Notes, Vol. 59, No. 4, 2011, FSU College of Law, Public Law Research Paper No. 522
Number of pages: 4 Posted: 15 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 67 (335,161)

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35.

The Canon that Tax Penalties Should Be Strictly Construed

Nevada Law Review, Vol. 3, p. 495, Spring 2003, FSU College of Law, Public Law Research Paper
Number of pages: 31 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 60 (354,485)

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36.

Unfinished Business on the Taxpayer Rights Agenda: Achieving Fairness in Transferee Liability Cases

Virginia Tax Review, Vol. 19, No. 3, 2000, FSU College of Law, Public Law Research Paper
Number of pages: 54 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 60 (354,485)

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37.

The IRS as Super Creditor

Tax Notes, Vol. 92, p. 655, 2007, FSU College of Law, Public Law Research Paper
Number of pages: 6 Posted: 22 Oct 2011 Last Revised: 24 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 58 (360,445)

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38.

Easterday and the Inability-to-Pay Defense to Tax Crimes

Tax Notes, Vol. 124, p. 787, 2009, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-03
Number of pages: 35 Posted: 18 Sep 2009 Last Revised: 10 Mar 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 55 (369,813)

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39.

The Phoenix and the Perils of the Second Best: Why Heightened Appellate Deference to Tax Court Decisions is Undesirable

Oregon Law Review, Vol. 77, 1998, FSU College of Law, Public Law Research Paper
Number of pages: 52 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 52 (379,356)

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40.

Deference to Tax Agencies' Interpretations of Their Regulations

State Tax Notes, Vol. 60, No. 9, 2011, FSU College of Law, Public Law Research Paper No. 524
Number of pages: 4 Posted: 15 Aug 2011 Last Revised: 01 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 52 (379,356)

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41.

Extraterritorial Audits, Tax Competitors, and Narratives: The Hyatt Case

State Tax Notes, Vol. 50, p. 283, 2008
Number of pages: 17 Posted: 04 Jun 2009 Last Revised: 06 Aug 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 51 (382,653)

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42.

Obamacare and the 'What is a Tax?' Question -- Part I

State Tax Notes, Vol. 63, No. 2, p. 155, January 2012, FSU College of Law, Public Law Research Paper No. 590
Number of pages: 5 Posted: 14 Apr 2012
Steve R. Johnson
Florida State University - College of Law
Downloads 49 (389,334)

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43.

Intermountain and the Importance of Administrative Law in Tax Law

Tax Notes, Vol. 128, p. 837, 2010, FSU College of Law, Public Law Research Paper
Number of pages: 16 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 46 (399,781)
Citation 1

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44.

Questionable Choices: A Reply to Alex Raskolnikov's 'Revealing Choices'

State Tax Notes, 2009, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 09-08
Number of pages: 12 Posted: 04 Jun 2009 Last Revised: 02 Jul 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 46 (399,781)

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tax compliance, Internal Revenue Service, tax audit

45.

The Reliance Defense: Advisor Conflicts and Taxpayer Knowledge

17 Journal of Tax Practice and Procedure, 49 (2015), FSU College of Law, Public Law Research Paper No. 775, FSU College of Law, Law, Business & Economics Paper No. 15-24
Number of pages: 6 Posted: 28 Oct 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 42 (414,260)

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46.

The Financial Inability Defense to Tax Crimes

ABA Section of Taxation News Quarterly, Vol. 23, No. 3, p. 6, Forthcoming, FSU College of Law, Public Law Research Paper
Number of pages: 2 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 41 (418,011)

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47.

Swallows as it Might Have Been: Regulations Revising Case Law

Tax Notes, Vol. 112, No. 9, August 28, 2006
Number of pages: 21 Posted: 25 Aug 2006 Last Revised: 30 Oct 2008
Steve R. Johnson
Florida State University - College of Law
Downloads 40 (421,875)

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Tax regulations

48.

Obamacare and the 'What is a Tax?' Question -- Part II

State Tax Notes, Vol. 63, No. 13, p. 1037, March 2012, FSU College of Law, Public Law Research Paper No. 591
Number of pages: 4 Posted: 14 Apr 2012
Steve R. Johnson
Florida State University - College of Law
Downloads 39 (425,830)

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49.

The E.L. Wiegand Lecture: Administrability-Based Tax Simplification

Nevada Law Review, Vol. 4, 2004, FSU College of Law, Public Law Research Paper
Number of pages: 36 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 39 (425,830)

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50.

The Duress or Deception Defense to Joint and Several Spousal Liability

Journal of Tax Practice and Procedure, Vol. 6, p. 15, 2005, FSU College of Law, Public Law Research Paper
Number of pages: 6 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 37 (434,035)

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51.

Pro-Taxpayer Interpretation of State-Local Tax Laws

State Tax Notes, p. 441, February 2009, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 36 (438,077)

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52.

Expert Witnesses and the Sixth Amendment

Tax Notes, Vol. 124, No. 1029, 2009
Number of pages: 11 Posted: 18 Sep 2009
Steve R. Johnson
Florida State University - College of Law
Downloads 36 (438,077)

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53.

The Rise and Fall of Chevron in Tax: From the Early Days to King and Beyond

2015 Pepperdine Law Review 19 (digital Symposium), FSU College of Law, Public Law Research Paper No. 813
Number of pages: 14 Posted: 26 Sep 2016
Steve R. Johnson
Florida State University - College of Law
Downloads 35 (442,256)

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54.

Elephants, Mouse Holes, Non-Barking Dogs, and Statutory Interpretations

State Tax Notes, p. 911, June 25, 2012, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 30 Mar 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 35 (442,256)

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55.

Extraterritorial Audits, Tax Competitors, and Narratives: Hyatt

State Tax Notes, p. 283, November 3, 2008, FSU College of Law, Public Law Research Paper
Number of pages: 7 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 35 (442,256)

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Is Lost Tax Revenue Property Under RICO?

State Tax Notes, Vol. 56, p. 307, 2010, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-29
Number of pages: 5 Posted: 21 Aug 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 21 (530,282)

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State Taxes, Local Taxes, Civil RICO

Is Lost Tax Revenue Property Under Rico?

State Tax Notes, p. 307, April 26, 2010, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 02 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 13 (582,320)

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57.

Reasoned Explanation and IRS Adjudication

63 Duke Law Journal 1771, 2014, FSU College of Law, Public Law Research Paper No. 733, FSU College of Law, Law, Business & Economics Paper No. 15-7
Number of pages: 64 Posted: 18 Feb 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 33 (450,730)

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58.

Cohen: Hard Case Makes (Semi) Bad Law

ABA Section of Taxation News Quarterly, p. 12, Fall 2011, FSU College of Law, Public Law Research Paper No. 560
Number of pages: 3 Posted: 29 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 33 (450,730)
Citation 1

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59.

Supermajority Provisions, Guinn v. Legislature and a Flawed Constitutional Structure

Nevada Law Review, Vol. 4, Spring 2004
Number of pages: 19 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 33 (450,730)

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60.
Downloads 32 (455,198)

After Craft: Implementation Issues

Tax Notes, Vol. 96, No. 4, p. 533, July 22, 2002
Number of pages: 16 Posted: 19 Jul 2002
Steve R. Johnson
Florida State University - College of Law
Downloads 21 (530,282)

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Taxation, federal tax laws

After Craft Implementation Issues

Tax Notes, Vol. 96, p. 553, 2002, FSU College of Law, Public Law Research Paper
Number of pages: 16 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 11 (596,108)

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Further Thoughts on Kanter and Ballard

Tax Notes, Vol. 105, No. 10, p. 1235, November 29, 2004
Number of pages: 12 Posted: 26 Nov 2004
Steve R. Johnson
Florida State University - College of Law
Downloads 21 (530,282)

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Tax, tax procedure, tax court rules

Further Thoughts on Kanter and Ballard

Tax Notes, Vol. 105, p. 1235, 2004, FSU College of Law, Public Law Research Paper
Number of pages: 12 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 10 (602,964)

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62.

Standing Issues in Tax Litigation

34 ABA Section of Taxation Newsquarterly 8, 2015, FSU College of Law, Public Law Research Paper No. 735
Number of pages: 3 Posted: 22 Feb 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 30 (464,618)

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63.

After Drye the Likely Attachment of the Federal Tax Lien to Tenancy-by-The Entireties Interests

Indiana Law Journal, Vol. 75, 2000, FSU College of Law, Public Law Research Paper
Number of pages: 28 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 30 (464,618)

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64.

The Anti-Injunction Act and the Individual Mandate

Tax Notes, Vol. 133, No. 11, December 12, 2011, FSU College of Law, Public Law Research Paper No. 593
Number of pages: 10 Posted: 18 Apr 2012
Steve R. Johnson
Florida State University - College of Law
Downloads 28 (474,379)

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65.

Why Craft Isn't Scary

Real Property, Probate and Trust Journal, Vol. 37, Fall 2002, FSU College of Law, Public Law Research Paper
Number of pages: 40 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 28 (474,379)

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66.

Swallows as it is: The Distortion of National Muffler

Tax Notes, Vol. 112, No. 351, 2006
Number of pages: 16 Posted: 30 Oct 2008
Steve R. Johnson
Florida State University - College of Law
Downloads 28 (474,379)

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Tax Rules and Regulations

67.

Reflections on Home Concrete: Writing Tax Regulations and Interpreting Tax Statutes

13 Florida State University Business Review 77 (2014), FSU College of Law, Public Law Research Paper No. 734
Number of pages: 17 Posted: 22 Feb 2015
Steve R. Johnson
Florida State University - College of Law
Downloads 27 (479,515)

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68.

Civil RICO and State and Local Taxes

State Tax Notes, Vol. 55, p. 711, 2010, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-28
Number of pages: 5 Posted: 21 Aug 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 27 (479,515)

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State Taxes, Local Taxes, Civil RICO

Living by the Initiative and Dying by the Initiative

State Tax Notes, Vol. 54, p. 809, 2009, UNLV William S. Boyd School of Law Legal Studies Research Paper No. 10-20
Number of pages: 5 Posted: 17 Aug 2010 Last Revised: 18 Aug 2010
Steve R. Johnson
Florida State University - College of Law
Downloads 16 (562,471)

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taxes, voter initiatives, grassroots, Mental Health Services Act, Proposition 63, equal protection, separation of powers

Living by the Initiative and Dying by the Initiative

State Tax Notes, p. 809, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 02 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 11 (596,108)

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Two Legislative Proposals: Give the Tax Court Case Transfer Power and Plenary Civil Tax Jurisdiction

Tax Notes, p. 1, July 21 2008, Florida State University - College of Law, Public Law Research Paper
Number of pages: 2 Posted: 01 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 16 (562,471)

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Two Legislative Proposals: Give the Tax Court Case Transfer Power and Plenary Civil Tax Jurisdiction

Tax Notes, July 2008, FSU College of Law, Public Law Research Paper
Number of pages: 2 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 10 (602,964)

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71.

Conditional Deference to Tax Authorities

State Tax Notes, p. 269, April 25, 2011, FSU College of Law, Public Law Research Paper
Number of pages: 2 Posted: 02 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 25 (490,292)

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72.

The Tax Lien and Entireties Interests: Evaluating the IRS's Implementation of Craft

Community Tax Law Report, Vol. 7, No. 1, p. 1, 2004, FSU College of Law, Public Law Research Paper
Number of pages: 10 Posted: 02 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 25 (490,292)

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73.

Targets Missed and Targets Hit: Critical Tax Studies and Effective Tax Reform

North Carolina Law Review, Vol. 76, 1998, FSU College of Law, Public Law Research Paper
Number of pages: 20 Posted: 20 Aug 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 25 (490,292)

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Interpreting State Tax Exemptions, Deductions, and Credits

State Tax Notes, p. 607, February 2009, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 25 (505,111)

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Interpreting State Tax Exemptions, Deductions, and Credits

State Tax Notes, Vol. 51, p. 607, 2009
Posted: 03 Jun 2009 Last Revised: 06 Aug 2009
Steve R. Johnson
Florida State University - College of Law

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tax statutes interpretation

75.

Do Treasury and the Service Have to Explain Their Choices?

ABA Section of Taxation News Quarterly, Vol, 30, No. 3, p.11, 2011, FSU College of Law, Public Law Research Paper No. 552
Number of pages: 3 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 24 (495,861)

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76.

The 'Things of the Same Nature' Canon in State Tax Construction

State Tax Notes, p. 60, January 7, 2013, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 31 Mar 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 22 (507,158)

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77.

The Judicial Instinct to Harmonize Statutes

State Tax Notes, p. 599, August 30, 2010, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 29 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 22 (507,158)

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78.

A Residual Damages Right Against the IRS: A Cure Worse than the Disease

Tax Notes, Vol. 88, No. 395, 2000, FSU College of Law, Public Law Research Paper
Number of pages: 13 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 22 (507,158)

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79.

State Tax Malpractive Actions: Statutes of Limitations

State Tax Notes, January 12, p. 119, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 21 (512,982)

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80.

Tax Shelters: Up Off the Canvas

FSU College of Law, Public Law Research Paper , ABA Section of Taxation Newsquarterly, Vol. 29, p. 1, 2010
Number of pages: 3 Posted: 21 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 21 (512,982)

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81.

The 'No Surplusage' Canon in State and Local Tax Cases

State Tax Notes, p. 793, September 17, 2012, FSU College of Law, Public Law Research Paper
Number of pages: 5 Posted: 31 Mar 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 20 (518,734)

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82.

New Light on Auer/Seminole Rock

State Tax Notes, p. 441, August 15, 2011, FSU College of Law, Public Law Research Paper
Number of pages: 2 Posted: 02 Nov 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 20 (518,734)

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83.

Tilted versus Reasonable Interpretation of Tax Laws

State Tax Notes, p. 277, October 2010, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 25 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 20 (518,734)

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84.

Following the APA Will Not Eliminate Useful Guidance

Tax Notes, January 2011, FSU College of Law, Public Law Research Paper No. 561
Number of pages: 2 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 20 (518,734)

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85.

Tax Advisor-Client Privilege: An Idea Whose Time Should Never Come

Tax Notes, Vol. 78, p. 1041, 1998, FSU College of Law, Public Law Research Paper
Number of pages: 4 Posted: 22 Oct 2011 Last Revised: 01 Jul 2016
Steve R. Johnson
Florida State University - College of Law
Downloads 19 (524,609)

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86.

Does Reliance on an Insider Provide Penalty Protection

Journal of Tax Practice and Procedure, Vol. 10, p. 35, 2008, FSU College of Law, Public Law Research Paper
Number of pages: 7 Posted: 22 Oct 2011 Last Revised: 24 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 19 (524,609)

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87.

Swallows Holding: Chevron's Growing Traction in Tax Litigation

ABA Section of Taxation Newsquarterly, Vol. 27, p. 1, 2008, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 21 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 19 (524,609)

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88.

It's Not a Tax (Statutorily), But It Is a Tax (Constitutionally)

American Bar Association, Section of Taxation, NewsQuarterly, p. 13, Fall 2012, FSU College of Law, Public Law Research Paper
Number of pages: 2 Posted: 02 Apr 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 18 (530,411)

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89.

Easterday and the 'Inability to Pay' Defense for Tax Crimes

Tax Notes, Vol. 124, p. 787, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 6 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 17 (536,240)

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90.

Further Thoughts on Interpreting Tax Statutes

ABA Section of Taxation Newsletter, Vol. 17, No. 4, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 29 Sep 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 17 (536,240)
Citation 1

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91.

Discovery in Summary Assessment Proceedings

Tax Notes, Vol. 93, p. 539, 2001, FSU College of Law, Public Law Research Paper
Number of pages: 7 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 15 (547,895)

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92.

What's Next in the Section 6501(E) Overstated Basis Controversy?

ABA Section of Taxation Newsquarterly, Vol. 20, p. 19, 2009, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 22 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 14 (553,952)

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93.

What Davis Means for Constitutional and Statutory Interpretation

State Tax Notes, p. 877, June 16, 2008, FSU College of Law, Public Law Research Paper
Number of pages: 12 Posted: 29 Oct 2011
Steve R. Johnson
Florida State University - College of Law
Downloads 12 (566,154)

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94.

ALJs in State-Local Tax Cases: To Whom is Deference Due?

State Tax Notes, June 11, pp. 785-789, 2012, FSU College of Law, Public Law Research Paper
Number of pages: 5 Posted: 03 Apr 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 10 (578,557)

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95.

Home Concrete: One Case, Two Perspectives

American Bar Association, Section of Taxation, Newsquarterly, p. 1, Summer 2012, FSU College of Law, Public Law Research Paper
Number of pages: 3 Posted: 02 Apr 2013
Steve R. Johnson
Florida State University - College of Law
Downloads 9 (584,819)

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96.

The Dangers of Symbolic Legislation: Perceptions and Realities of the New Burden-of-Proof Rules

Iowa Law Review, Vol. 84, 413, 1999
Posted: 06 Sep 1999
Steve R. Johnson
Florida State University - College of Law

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