Julie A.D. Manasfi (Loyola-L.A.) has published Potentially the Last Word in Judicial Review — A Look at Certain Fifth Circuit Tax Cases, 40 Tex. Tech L. Rev. 787 (2008). Here is part of the Introduction
Twelve cases involving tax were decided by the Fifth Circuit Court of Appeals during the survey period — June 1, 2006, through May 31, 2007. These cases are summarized and briefly discussed below. Of the twelve cases, only five are truly controversies concerning the correct amount of taxes. Two cases concern criminal procedure and sentencing. The remaining five cases concern challenges to IRS discretion, notices, and levies.
