Notice & Comment

Author: Jonathan H. Choi

Notice & Comment

Are Agencies Really More Purposivist than Courts?

Yes, at least in tax law. The IRS has resisted the trend of the past few decades toward textualism, unlike the Tax Court, which has grown more textualist alongside other federal courts. This and more can be found in An Empirical Study of Statutory Interpretation in Tax Law, an article I recently posted to SSRN. […]

Notice & Comment

The Most-Cited Tax Articles of All Time

Summer is nearly here, and for fellow tax nerds in need of beach reads, I’ve assembled a list of the 50 most widely cited tax law journal articles. The list is inspired by (and uses the same methodology as) Fred Shapiro and Michelle Pearse’s essay, The Most-Cited Law Review Articles of All Time. The list […]