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A World of Taxpayers? It's Not a Small World after All

80 Pages Posted: 7 Dec 2005  

Richard Lavoie

University of Akron - School of Law


This paper closely examines the language, history and intent underlying the Internal Revenue Code to develop a paradigm for analyzing the extent to which foreigners are subject to the tax laws of the United States. The paper concludes that while some Code provisions were clearly intended to have a broad scope, most others should be read with a significantly more narrow focus. Central to the resolution of such matters is the use of the term "taxpayer" in the Internal Revenue laws. This paper demonstrates that, contrary to certain judicial and administrative dicta, applying the term taxpayer with a circumscribed and contextual meaning can provide a reasoned basis for determining the proper scope of specific U.S. tax provisions.

Keywords: taxpayer, statutory interpretation

Suggested Citation

Lavoie, Richard, A World of Taxpayers? It's Not a Small World after All. University of Missouri - Kansas City Law Review, Vol. 70, p. 545, 2002; U of Akron Legal Studies Research Paper No. 05-23. Available at SSRN:

Richard Lavoie (Contact Author)

University of Akron - School of Law ( email )

150 University Ave.
Akron, OH 44325-2901
United States

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