Add to ORKGThe Fifth Circuit chose to recognize a judicially-created exception to the statute in Johnson v. Sawyer. This Note takes issue with the Fifth Circuit\u27s holding in Johnson. The IRS is a creature of statute and, as such, should be governed by statute. If any further life is given the agency, it is for Congress, and not the judiciary to declare. If taxpayers convicted in the Fifth Circuit are to have their transgressions publicized, it should be with the specific approval of their elected representatives. Part I of this Note traces the development of judiciallycreated exceptions to I.R.C. § 6103 in the federal circuits. Part II reviews Johnson at its various levels and analyzes the reasoning of the Fifth Circuit in finding an exception to t...
(Excerpt) The Anti–Injunction Act is a provision of the U.S Code that prohibits any court from imped...
Section 6851 of the Internal Revenue Code of 1954 allows the Internal Revenue Service to close a tax...
Treasury regulations defining the duties of those practicing before the IRS, commonly called Circula...
The Fifth Circuit chose to recognize a judicially-created exception to the statute in Johnson v. Saw...
This Note argues that creating a tax-crime exception to the privilege against self-incrimination cou...
For all practical purposes, the Constitution prescribes only one limit on the federal government\u27...
Over twenty years ago, Congress took the extraordinary step of authorizing taxpayers to sue the Inte...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...
Can one Congress tie the hands of a later Congress? That is the issue posed by legislative entrench...
When a taxpayer files an honest\u27 federal income tax return for a taxable year, section 6501(a) of...
This Article argues that revenue rulings should be treated consistently in all judicial fora. The di...
In Hall v. United States, the Supreme Court of the United States granted certiorari upon the petitio...
Taxpayer standing has generally been prohibited by a line of Supreme Court cases with one narrow exc...
When the collection of tax could be imperiled by going through the usual deficiency procedures, the ...
In the early 1980\u27s, Congress faced the mounting problems of tax shelters and other forms of tax ...
(Excerpt) The Anti–Injunction Act is a provision of the U.S Code that prohibits any court from imped...
Section 6851 of the Internal Revenue Code of 1954 allows the Internal Revenue Service to close a tax...
Treasury regulations defining the duties of those practicing before the IRS, commonly called Circula...
The Fifth Circuit chose to recognize a judicially-created exception to the statute in Johnson v. Saw...
This Note argues that creating a tax-crime exception to the privilege against self-incrimination cou...
For all practical purposes, the Constitution prescribes only one limit on the federal government\u27...
Over twenty years ago, Congress took the extraordinary step of authorizing taxpayers to sue the Inte...
In United States v. Carlton, the Supreme Court rejected a Due Process challenge to the retroactive e...
Can one Congress tie the hands of a later Congress? That is the issue posed by legislative entrench...
When a taxpayer files an honest\u27 federal income tax return for a taxable year, section 6501(a) of...
This Article argues that revenue rulings should be treated consistently in all judicial fora. The di...
In Hall v. United States, the Supreme Court of the United States granted certiorari upon the petitio...
Taxpayer standing has generally been prohibited by a line of Supreme Court cases with one narrow exc...
When the collection of tax could be imperiled by going through the usual deficiency procedures, the ...
In the early 1980\u27s, Congress faced the mounting problems of tax shelters and other forms of tax ...
(Excerpt) The Anti–Injunction Act is a provision of the U.S Code that prohibits any court from imped...
Section 6851 of the Internal Revenue Code of 1954 allows the Internal Revenue Service to close a tax...
Treasury regulations defining the duties of those practicing before the IRS, commonly called Circula...