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Browsing Law Faculty Scholarship by Author "Camp, Bryan T."

Browsing Law Faculty Scholarship by Author "Camp, Bryan T."

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  • Camp, Bryan T. (2015)
    Treasury has historically regulated a group called “tax practitioners” through the regulations contained in Circular 230. These regulations are issued under the authority of 31 U.S.C. §330 which permits Treasury to regulate ...
  • Camp, Bryan T. (Tax Notes, 2004)
    Professor Camp explains the inquisitorial nature of the process of Tax Administration and argues that, regardless of what the nature of the process is, it must be fair.
  • Camp, Bryan T. (Tax Notes, 2010-08)
    Like fences, the statutes in subtitle F of the Tax Code define the operational area in which the IRS administers the tax laws. Statutory words - like pickets - place important boundaries on IRS action. Statutory silence - ...
  • Camp, Bryan T. (Tax Notes, 2012-06-25)
    This article examines the tax collection process to see how the IRS might enforce the individual mandate under the healthcare reform law. It concludes that resistant taxpayers can generally be forced to pay the tax penalty ...
  • Camp, Bryan T. (Lexis, 2003)
    Professor Camp’s treatise chapter cites and explains the statutory mitigation provisions of the Internal Revenue Code and the judicial doctrines of equitable estoppel and equitable recoupment.
  • Camp, Bryan T. (Lexis, 2003)
    Professor Camp’s treatise chapter highlights the reasoning for imposing limitation periods and then explains limitation periods for various actions.
  • Camp, Bryan T. (2013)
    In 2011, the Department of Treasury issued regulations that, for the most time, empowered the IRS to regulate the practice of preparing tax returns. Naturally, many tax return prepares were not happy about being regulated ...
  • Camp, Bryan T. (Tax Notes, 2007)
    In FY2005, the IRS refunded about $227.6 billion to individual taxpayers. Given the huge amounts involved, even small error rates add up. For example, even if the IRS had an error rate of just 1% that would mean $2.2 billion ...
  • Camp, Bryan T. (Tax Notes, 2006)
    In every era and area of law you find a never-ending battle between two groups of legal thinkers: formalists and functionalists. Each is connected to long-standing and honorable traditions in Anglo- American jurisprudence. ...
  • Camp, Bryan T. (2015-04-14)
    The Internal Revenue Service takes a lot of hits, both from those who are paid to be critics like the National Taxpayer Advocate and from those who just pile on for the fun of it—politicians, pundits, and the public. The ...
  • Camp, Bryan T. (2007)
    Taxation is shadow life. As our culture monetizes more and more life activities, the shadow grows. This article looks at the potential tax issues arising from a new life activity: online role-playing games in virtual worlds. ...
  • Camp, Bryan T. (Tax Notes, 2008)
    Just because the IRS has the legal authority to act, argues Professor Camp, does not mean that it should. The Tax Court's decision in Allen v. Commissioner, where the court agreed to let the IRS use old language for a new ...
  • Camp, Bryan T. (Tax Notes, 2007)
    In tax law and theory, procedure gets short shrift. Yet sometimes, procedure makes all the difference. That seems to me to be particularly true regarding the recent publicity over the tax consequences of foreclosures on ...
  • Camp, Bryan T. (Estate Planning & Community Property Law Journal, 2009)
    One common issue facing those who create trusts is how to protect beneficiaries from creditors. One of the biggest, baddest creditors out there is the Internal Revenue Service (IRS or Service), wielding two weapons of mass ...
  • Camp, Bryan T. (Tax Notes, 2005)
    Professor Camp argues that the collection due process of Tax Administration is the wrong solution to an erroneous problem and then proceeds to give the correct answer to the actual problem.
  • Camp, Bryan T. (Virginia Tax Review, 1988)
    Professor Camp, then a student, analyzes ways in which courts may find abuse of discretion under § 7805(b) of the Internal Revenue Code, which creates a presumption of retroactivity of any ruling by the IRS.
  • Camp, Bryan T. (Florida Law Review, 2004)
    In this Article, Professor Camp pursues three goals. The first is to describe and justify the inquisitorial nature of tax administration. He offers the conception of tax administration as two related but distinct functions: ...
  • Camp, Bryan T. (Tax Notes, 2007)
    Professor Camp’s thesis is that the section 6501(a) assessment limitation period represents a very strong public policy choice in favor of closure, far stronger than a typical statute of limitation. Accordingly, he believes ...
  • Camp, Bryan T. (Lexis, 2003)
    Professor Camp’s treatise chapter focuses on the procedure for a refund claim and limitations for refund claims, amounts that can be recovered, and refund suits.
  • Camp, Bryan T. (Virginia Tax ReviewVirginia Tax Review, 2009)
    This article concerns the history of automation in U.S. tax administration and the challenges automation presents to administering the laws consistent with democratic values. The most under-theorized aspect of tax ...