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Articles
Reasonable Relation Reassessed: The Examination of Private Documents by Federal Regulatory Agencies, 56 NEW YORK UNIVERSITY LAW REVIEW 742 (1981). [HeinOnline]
The Taxpayer's Duty of Consistency, 46 TAX LAW REVIEW 537 (1991). [HeinOnline]
Fog, Fairness, and the Federal Fisc: Tenancy-by-the-Entireties Interests and the Federal Tax Lien, 60 MISSOURI LAW REVIEW 839 (1995). [HeinOnline]
Writer Says Tax Liens Should Attach to Tenancy-by-the-Entireties Interests, 96 TAX NOTES TODAY 68-18 (1996).
The Phoenix and the Perils of the Second Best: Why Heightened Appellate Deference to Tax Court Decisions Is Undesirable, 77 OREGON LAW REVIEW 235 (1998). [HeinOnline]
The Proposed Tax Advisor-Client Privilege: An Idea Whose Time Should Never Come, 78 TAX NOTES 1041 (1998).
Targets Missed and Targets Hit: Critical Tax Studies and Effective Tax Reform, 76 NORTH CAROLINA LAW REVIEW 1771 (1998). [HeinOnline]
Tax Profs Urge Rejection of Burden-of-Proof Shift, (with others), 78 TAX NOTES 755 (1998).
The Dangers of Symbolic Legislation: Perceptions and Realties of the New Tax Burden-of-Proof Rules, 84 IOWA LAW REVIEW 413 (1999). [HeinOnline]
After Drye: The Likely Attachment of the Federal Tax Lien to Tenancy-by-the-Entireties Interests, 75 INDIANA LAW JOURNAL 1163 (2000). [HeinOnline]
A Residual Damages Right Against the IRS: A Cure Worse than the Disease, 88 TAX NOTES 395 (2000).
Supreme Court Tax Jurisprudence Isn’t All Bad, 87 TAX NOTES 855 (2000).
Unfinished Business on the Taxpayer Rights Agenda: Achieving Fairness in Transferee Liability Cases, 19 VIRGINIA TAX REVIEW 403 (2000). [HeinOnline]
Discovery in Summary Assessment Proceedings, 93 TAX NOTES 539 (2001).
Federal Tax Collection in the Era of Drye, 9 NEVADA LAWYER 15 (October 2001). [HeinOnline]
The IRS as Super Creditor, 92 TAX NOTES 655 (2001) .