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

31 Pages Posted: 13 Jul 2016

See all articles by Leandra Lederman

Leandra Lederman

Indiana University Maurer School of Law

Date Written: 2001

Abstract

This article is a reply to Marcus Schoenfeld's article, "A Critique of the Internal Revenue Service's Refusal to Disclose How It 'Determined' a Tax Deficiency, and of the Tax Court's Acquiescence with This View," 33 Ind. L. Rev. 517 (2000). Professor Schoenfeld argued that a combination of factors conspire to hinder taxpayers' defense of civil tax cases, particularly cases involving allegations of fraud. His concerns center on taxpayer access to IRS information and IRS techniques for proving tax fraud. This reply tackles each of those sets of issue in turn, arguing that in many contexts, existing checks on the IRS are sufficient, but also recommending specific improvements to some aspects of the tax controversy process.

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

JEL Classification: H26, K34, K41, K42

Suggested Citation

Lederman, Leandra, Are There Procedural Deficiencies in Tax Fraud Cases? A Reply to Professor Schoenfeld (2001). 35 Ind. L. Rev. 143 (2001), Available at SSRN: https://ssrn.com/abstract=2808162

Leandra Lederman (Contact Author)

Indiana University Maurer School of Law ( email )

211 S. Indiana Avenue
Bloomington, IN 47405
United States
(812) 855-6149 (Phone)
(812) 855-0555 (Fax)

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

Here is the Coronavirus
related research on SSRN

Paper statistics

Downloads
18
Abstract Views
517
PlumX Metrics