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College of Law

Florida State University


Business Law Faculty

Our business and tax faculty members are prolific scholars with experience as partners or associates at some of the nation’s top corporate law firms.

Steve R. Johnson

Steve R. Johnson

Dunbar Family Professor

Florida State University
College of Law
Rotunda, Room R203
Phone: 850.644.1777


J.D., New York University, 1981
B.A., St. Francis College (New York), 1976

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Professor Steve Johnson is a nationally recognized scholar on tax litigation and procedure, including legislative and administrative law topics in tax. Among other courses, he teaches Income Taxation, Taxation of Business Entities, Business Planning, International Tax and Administrative Law. His publications include two casebooks, Civil Tax Procedure (2d ed., Lexis-Nexis 2008) (with David Richardson & Jerome Borison) and Tax Crimes (Lexis-Nexis 2008) (with Scott Schumacher, Larry Campagna & John Towensend), as well as numerous articles on tax procedure and tax law. He is a columnist for State Tax Notes and an associate editor of the American Bar Association Section of Taxation NewsQuarterly.

Johnson practiced tax law in New York City, after which he served as a senior attorney with the IRS Chief Counsel’s Office and a Special Assistant United States Attorney. He also has taught at Indiana University School of Law-Bloomington, the University of Nevada, Las Vegas School of Law and the University of Alabama School of Law, and has visited at Chicago-Kent College of Law and the University of California Hastings College of the Law.

Select Recent Publications

CIVIL TAX PROCEDURE (with Jerome Borison & Samuel Ullman) (3d ed., Carolina Academic Press 2016)

TAX CRIMES (with John Townsend, Larry Campagna & Scott Schumacher) (2d ed., LexisNexis 2015)

After Loving: How Much of Circular 230 Will Survive?, in Duties to the Tax System (University of Washington School of Law 2015)

Imputed Rental Income: Reality Trumps Theory, in Controversies in Tax Law: A Matter of Perspective (Anthony Infanti, editor) (Ashgate Publishing 2015)

Legal Interpretation of Tax Law: United States, in Legal Interpretation of Tax Law (Robert van Brederode & Richard Krever, editors) (2d ed., Kluwer Law International 2017)

Tax Penalties in the United States (with Leandra Lederman & Stephen Mazza), in Surcharges and Penalties in Tax Law (European Association of Tax Law Professors 2016)

The Upsides and Downsides of Ending Chevron Deference, 154 Tax Notes 1287 (2017)

Standing Doctrine in State Tax Controversies, 83 State & Local Tax Notes 24 (2017)

Seminole Rock in Tax Cases, Yale J. Reg.: Notice & Comment (2016)

Is an American Value Added Tax Inevitable?
, 15 Fla. St. U. Bus. Rev. 1 (2016)

The Future of American Tax Administration: Conceptual Alternatives and Political Realities, 7 Colum. J. Tax L. 5 (2016)

Retroactive Tax Legislation, 81 State & Local Tax Notes 529 (2016)

The Rise and Fall of Chevron in Tax: From the Early Days to King and Beyond, 2015 Pepp. L. Rev. 14

The Reliance Defense: Advisor Conflicts and Taxpayer Knowledge, 17/4 J. Tax Prac. & Proc. 49 (Aug.-Sept. 2015)

How Would the Supreme Court Rule on Loving and Ridgely?, 147 Tax Notes 559 (2015)

How Far Does Circular 230 Exceed Treasury’s Statutory Authority?, 146 Tax Notes 221 (2015)

Loving and Legitimacy, 59 Vill. L. Rev. 515 (2014)

Reflections on Home Concrete, 13 Fla. St. U. Bus. Rev. 75 (2014)

Reasoned Explanation and IRS Adjudication, 63 Duke L.J. 1771 (2014)