Directory

Bibliography

Works in Progress

Comments on Proposed Regulations: 'Contributions in Exchange for State or Local Tax Credits' (Reg-112176-18) (September 6, 2018)

Books

Federal Income Taxation (Aspen Publishing, 2004, 2d ed. 2007; Wolters Kluwer Law & Business, 3d ed. 2011; Wolters Kluwer, 4th ed. 2015, 5th ed. 2018, 6th ed. 2023) (with others)
Federal Income Taxation: A Law Student's Guide to the Leading Cases and Concepts (Concepts and Insights Series) (Foundation Press, 12th ed. 2012, 13th ed. 2015, 14th ed. 2018, 15th ed. 2023) (with Marvin A. Chirelstein)
A Half-Century With the Internal Revenue Code: The Memoirs of Stanley S. Surrey (Carolina Academic Press, 2022) (editor with Ajay Mehrotra)
Figuring Out the Tax: Congress, Treasury, and the Design of the Early Modern Income Tax (Cambridge University Press, 2018)
Learning to Love Form 1040: Two Cheers for the Return-Based Mass Income Tax (University of Chicago Press, 2013)
Federal Income Taxation of Individuals—Study Problems (1990, 2d ed. 1996, 3d ed. 2003) (with Martin J. McMahone, Jr. & Boris Bitker) (with Teacher's Manuals)
Federal Income Taxation of Individuals (3d ed. 2002) (with others)

Articles & Essays

Stanley Surrey and Taxing Unrealized Appreciation, 86 Law and Contemporary Problems 153-165 (2023)
Reading the Taxpayers' Brief in Moore, 112 Tax Notes International 77-82 (2023)
What We Talk About When We Talk About Tax Shelters, 108 Iowa Law Review Online 130-143 (2023)
Foreword: The Legacy of Stanley S. Surrey, 86 Law and Contemporary Problems i-xii (2023) (with Ajay K. Mehrotra)
The Income Tax, the Constitution, and the Unrealized Importance of Helvering v. Griffiths, 43 Virginia Tax Review 257-290 (2023)
Stanley S. Surrey: A Life in Taxes, 175 Tax Notes Federal 741-749 (2022) (with Ajay K. Mehrotra)
The Two "Two Americas" of Trump and Romney, 85 Law and Contemporary Problems 87-100 (2022)
1924, 2021: Taxes of the Ultrarich, and Mark-to-Market Reforms, 172 Tax Notes Federal 583-592 (2021)
The American Families Plan and the Future of the Mass Income Tax, 172 Tax Notes Federal 1277- 1288 (2021)
The Deductibility of Capital Losses in a Mark-to-Market Regime, 172 Tax Notes Federal 1965-1972 (2021)
Examining the Internal Revenue Code for Disparate Racial Impacts, 168 Tax Notes Federal 1807-1821 (2020)
Giving Credits Where Credits Are (Arguably) Due: A Half Century's Evolution in the Design of Personal Tax Expenditures, 24 Florida Tax Review 51-150 (2020)
Seven-Plus Decades of the Federal Income Tax in Sitcoms: An Update, 167 Tax Notes Federal 1211-1215 (2020)
“We Will See That You Are Troubled Right Along”: Women and the Politics of the Early Federal Income Tax, 27 Duke Journal of Gender Law & Policy 279-295 (2020)
Tax in History: The Federal Income Tax Goes to War, 47 Intertax 766-769 (2019)
The NCAA and the IRS: Life at the Intersection of College Sports and the Federal Income Tax, 92 Southern California Law Review 1087-1153 (2019) (with Richard L. Schmalbeck)
Foreword: The Past, Present, and Future of the Federal Tax Legislative Process, 81 Law and Contemporary Problems 1-6 (2018) (with George K. Yin)
Leaving it up to Treasury: Congressional Abdication on Major Policy Issues in the Early Years of the Income Tax, 81 Law and Contemporary Problems 137-165 (2018)
SALT Ceiling Workarounds and Tax Shelters, 160 Tax Notes 521-535 (2018)
The Body in Question: The Income Tax and Human Body Materials, 80 Law & Contemporary Problems 37-82 (No. 1 2017)
For Better and Worse: The Differing Income Tax Treatments of Marriage at Different Income Levels, 93 North Carolina Law Review 783-820 (2015)
In Memoriam: Marvin and Zeno, 149 Tax Notes 311-319 (2015)
Maybe Just a Little Bit Special, After All?, 63 Duke Law Journal 1897-1920 (2014)
Mitt Romney, the 47% Percent, and the Future of the Mass Income Tax , 67 Tax Law Review 471-500 (2013-2014)
Tearing Out the Income Tax by the (Grass)Roots, 15 Florida Tax Review 649-673 (2014) (reviewing Isaac William Martin, Rich People’s Movements: Grassroots Campaigns to Untax the One Percent (2013))
The Almost-Restatement of Income Tax of 1954: When Tax Giants Roamed the Earth, 79 Brooklyn Law Review 709-732 (2014)
Up in the Air Over Taxing Frequent Flyer Benefits: The American, Canadian, and Australian Experiences, 9 Capital Markets Law Journal 420-446 (2014)
Will the Federal Income Tax Have a Bicentennial?, 41 Florida State University Law Review 275-290 (2014)
The Federal Income Tax in Situation Comedies, Proceedings 104th Annual Conference on Taxation 7-12 (2013)
Choosing Between Tax and Nontax Delivery Mechanisms for Health Insurance Subsidies, 65 Tax Law Review 723-747 (2012)
Custom and the Rule of Law in the Administration of the Income Tax, 62 Duke Law Journal 829-855 (2012)
The Great American Tax Novel, 110 Michigan Law Review 969-984 (2012) (reviewing David Foster Wallace, The Pale King (2011))
Tax Scholarship: Useful and Useless, 130 Tax Notes 1337-1341 (2011)
The Loophole that Would Not Die: A Case Study in the Difficulty of Greening the Internal Revenue Code, 15 Lewis & Clark Law Review 469-481 (2011)
Of Punitive Damages, Tax Deductions, and Tax-aware Juries: A Response to Polsky and Markel, 96 Virginia Law Review In Brief 61-68 (2010)
Tax Increases, Revenue Effects, Efficiency, and Income Inequality, 128 Tax Notes 197-204 (2010) (with Marvin A. Chirelstein)
Complex Tax Legislation in the Turbotax Era, 1 Columbia Journal of Tax Law 91-119 (2010)
Debt-Financed Consumption and a Hybrid Income-Consumption Tax, 64 Tax Law Review 1-35 (2010)
Foreword: The Fabulous Invalid Nears 100, 73 Law and Contemporary Problems i-xvii (Winter 2010)
The Federal Retail Sales Tax that Wasn't: An Actual History and an Alternative History, 73 Law and Contemporary Problems 149-205 (Winter 2010)
Tax Enforcement for Gamers: High Penalties or Strict Disclosure Rules?, 109 Columbia Law Review Sidebar 55 (2009)
Codification of General Disallowance of Artificial Losses, 122 Tax Notes 1389-1392 (2009) (with Calvin H. Johnson)
Tax Expenditures and the Carbon Audit, 122 Tax Notes 1367-1376 (2009)
Can Obama's IRS Retroactively Revoke Massive Bank Giveaway?, 122 Tax Notes 889-893 (2009)
Cancellation-of-Indebtedness Income and Transactional Accounting, 29 Virginia Tax Review 277 (2009)
Does Intergenerational Justice Require Rising Standards of Living?, 77 George Washington Law Review 1358-1382 (2009)
Tax Policy and Personal Identity Over Time, 62 Tax Law Review 333-375 (2009)
The Conscientious Legislator and Public Opinion on Taxes, 40 Loyola University of Chicago Law Journal 369-383 (2009)
The Court and the Code: A Response to 'The Warp and Woof of Statutory Interpretation', 58 Duke Law Journal 1783-1789 (2009)
Six Decades of the Federal Income Tax in Sitcoms, 117 Tax Notes 1265-1288 (2007)
Justice Holmes, Ralph Kramden, and the Civic Virtues of a Tax Return Filing Requirement, 61 Tax Law Review 53-88 (2007)
The Theory and Practice of Tax Reform, 105 Michigan Law Review 1133-1149 (2007) (reviewing The President's Advisory Panel on Federal Tax Reform. Simple, Fair, and Pro-Growth: Proposals to Fix America's Tax System (2005))
Of Head Taxes, Income Taxes, and Distributive Justice in American Health Care, 69 Law and Contemporary Problems 103-120 (Autumn 2006)
Taxing Endowment, 55 Duke Law Journal 1145-1181 (2006)
The Declining Progressivity of the Federal Income Tax, in Law and Class in America: Trends Since the Cold War 163-190 (Paul D. Carrington & Trina Jones eds, 2006)
The Sometimes-Taxation of the Returns to Risk-Bearing Under a Progressive Income Tax, 59 SMU Law Review 879-915 (2006)
Of Prius Buyers, Blue States, Consumer Energy Credits, and the Alternative Minimum Tax, 109 Tax Notes 657-662 (2005)
Tax or Welfare? The Administration of the Earned Income Credit, 52 UCLA Law Review 1867-1916 (2005)
Tax Shelters and the Search For the Silver Bullet, 105 Columbia Law Review 1939-1966 (2005) (with Marvin Chirelstein)
The Story of Seagram: The Step Transaction Doctrine on the Rocks, in Business Tax Stories 263-293 (Steven A. Bank & Kirk J. Stark eds, 2005)
Framing the Distributional Effects of the Bush Tax Cuts, 105 Tax Notes 83-95 (2004)
Redesigning the Earned Income Tax Credit as a Family-Size Adjustment to the Minimum Wage, 57 Tax Law Review 301-353 (2004)
The Myth of Pretax Income, 101 Michigan Law Review 2261-2274 (2003) (reviewing Liam Murphy and Thomas Nagel, The Myth of Ownership: Taxes and Justice (2002))
A Whirlwind Tour of the Internal Reveune Code's At-Risk and Passive Activity Loss Rules, 36 Real Property, Probate & Trust Journal 673-730 (2002) (with others)
Capitalization of Benefits Beyond the Tax Year, 97 Tax Notes 257-264 (2002) (with others)
The Income Tax and the Costs of Earning a Living, 56 Tax Law Review 39-79 (2002)
A Health Insurance Tax Credit for Uninsured Workers, 38 Inquiry 106-120 (2001)
Codifying Anti-avoidance Doctrines and Controlling Corporate Tax Shelters, 54 SMU Law Review 177-193 (2001)
Doing Something about Marriage Penalties: a Guide for the Perplexed, 54 Tax Law Review 1-76 (Fall 2000)
The Puzzling Case of the Revenue-maximizing Lottery, 79 North Carolina Law Review 1-43 (2000)
Can the Graduated Income Tax Survive Optimal Tax Analysis?, 53 Tax Law Review 51-93 (1999) (with Kemper Moreland)
Radical Tax Reform, the Constitution, and the Conscientious Legislator, 99 Columbia Law Review 833-855 (1999)
Taxing Baseballs and Other Found Property, 84 Tax Notes 1299-1308 (1999) (with Martin J. McMahon Jr.)
The Selling of the Flat Tax: the Dubious Link Between Rate and Base, 85 Tax Notes 1177-1195 (1999)
Feminism and "Safe Subjects Like the Tax Code", 6 Southern California Review of Law & Women's Studies 323-327 (1998)
Taking Critical Tax Theory Seriously, 76 North Carolina Law Review 1521-1580 (1998)
Children and the Income Tax, 49 Tax Law Review 349-418 (1997) (excerpted in Tax Policy Readings and Materials 411-420 (Philip D. Oliver & Fred W. Peel, Jr. eds., 1996), and in, Federal Income Tax Anthology 152-156 (Paul L. Caron, Karen C. Burke & Grayson M.P. Mccouch eds., 1997))
Do Anti-Tax Shelter Rules Make Sense? A Reply to Professor Johnson, 68 Texas Law Review 491-507 (1997) (excerpted in Federal Income Tax Anthology 405-09 (Paul L. Caron, Karen C. Burke & Grayson M.P. McCouch eds., 1997))
Tax and the Married Woman, 70 Southern California Law Review 1021-1048 (1997) (reviewing Edward J. McCaffery, Taxing Women (1997))
Thinking about Nonliteral Interpretations of the Internal Revenue Code, 64 North Carolina Law Review 623-676 (1997) (excerpted in Federal Income Tax Anthology 29-35 (Paul L. Caron, Karen C. Burke & Grayson M.P. McCouch eds., 1997))
Commentary: the Reasons for a Consumption Tax and the Tax Treatment of Gifts and Bequests, 51 Tax Law Review 601-613 (1996)
I Can Sit on It, but Is it Art?, 70 Tax Notes 99-103 (1996)
Flat Tax vs. VAT: Progressivity and Family Allowances, 68 Tax Notes 1129-1134 (1995)
The Reification of Metaphor: Income Taxes, Consumption Taxes and Human Capital, 51 Tax Law Review 1-34 (1995)
Marriage and the Income Tax, 67 Southern California Law Review 339-405 (1994)
Taxing Gains at Death, 59 Tax Notes 287-289 (1993)
Does Treasury Have Authority to Index Basis for Inflation?, 55 Tax Notes 841-845 (1992) (reprinted in The Capital Gains Controversy: A Tax Analysts Reader 521-525 (J. Andrew Hoerner ed., 1992), and in, Selected Reading on Tax Policy: 25 Years of Tax Notes 246-250 (Charles Davenport ed., 1997))
Reforming Penalty Reform: Congress Should Eliminate the Profusion of Accuracy Standards, 52 Tax Notes 471-477 (1991)
The Taxation of Tax Indemnity Payments: Recovery of Capital and the Contours of Gross Income, 46 Tax Law Review 381-403 (1991)
Are Rifle Shot Transition Rules and Other Ad Hoc Tax Legislation Constitutional, 44 Tax Law Review 563-625 (1989)
When Good Preferences Go Bad: A Critical Analysis of the Anti-Tax Shelter Provisions of the Tax Reform Act of 1986, 67 Texas Law Review 499-589 (1989) (excerpted in Federal Income Tax Anthology 394-400 (Paul L. Caron, Karen C. Burke & Grayson M.P. McCouch eds., 1997))
Should Courts Require the Internal Revenue Service to be Consistent?, 40 Tax Law Review 411-448 (1985)
The Tax Exempt Status of Communitarian Religious Organizations: An Unnecessary Controversy?, 50 Fordham Law Review 1085-1112 (1985) (reprinted in 36 AAR Studies in Religion 177-201 (1985)) (with Meade Emory)
Serving Two Masters: Commercial Hues and Tax Exempt Organizations, 8 University of Puget Sound Law Review 1-23 (1984)

Issues Edited

The Legacy of Stanley S. Surrey, 86 Law and Contemporary Problems (No. 2, 2023) (with Ajay K. Mehrotra)
The Past, Present, and Future of the Federal Tax Legislative Process, 81 Law and Contemporary Problems (No. 2, 2018) (with George K. Yin)
Turning Points in the History of the Federal Income Tax, 73 Law and Contemporary Problems (No. 1, Winter 2010)

Newspaper Articles and Commentary

SALT Ceiling Workarounds and Tax Shelters, Revisited, 160 Tax Notes (August 6, 2018, at 841)
How Congress Could Have Spared Us Tax-Day Headaches, BloombergView (May 8, 2013)
U.S. Income Tax -- 100 Years Old, and Almost Never Happened, The Globe and Mail (April 11, 2013)
When We Loved Form 1040, New York Times (April 1, 2013)

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Directory

Bibliography

Works in Progress

Books

Articles & Essays

Issues Edited

Newspaper Articles and Commentary

Lawrence A. Zelenak