Danshera Cords (Capital) presents Is Tax Special:  Administrative Law and Judicial Review of IRS Collection Decisions at Capital today as part of its Faculty Lecture Series.  Here is the abstract:

This article challenges the notion that in the context of tax litigation challenging tax collection decisions it is hard to make a serious case that rules different from those applicable to the review of other agency actions is warranted or necessary. Nonspecialists, such as judges in the district courts, the Circuit Courts of Appeals, and even the United States Supreme Court regularly handle complex questions relating to the determination of the amount of tax properly owed by a taxpayer. Thus, tax litigation should be conducted in the same manner as other litigation, except where Congress has provided otherwise.