Tax Administration as Inquisitorial Process & the Partial Paradigm Shift in the IRS Restructuring and Reform Act of 1998

The tax code is a puzzle. Whether one views it as an engaging enigma or a ridiculous riddle, the tax code requires careful and considered attention to fit the statutory pieces together to form a sensible picture. The procedural pieces of the puzzle, however, are often neglected by taxwriters and academics. This Article address that neglect to show how a study of tax administration can add value to the study of both tax law and administrative law. <br><br>In this Article, I pursue three goals. The first is to describe and justify the inquisitorial nature of tax administration. I offer the conception of tax administration as two related but distinct functions: tax determination and tax collection, both of which employ inquisitorial processes. I suggest that the justification for the use of these processes lies in the government's need for information to ensure that all taxpayers pay their proper tax and thereby encourage voluntary compliance. My second goal is to show how certain pr