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College of Law

Florida State University

 

Faculty

Steve R. Johnson

Steve R. Johnson

Dunbar Family Professor

Florida State University
College of Law
Rotunda, Room R213
Phone: 850.644.1777
sjohnson@law.fsu.edu

Education

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)

Tax Statutory Interpretation in the United States, in Legal Interpretation of Tax Law (Robert van Brederode & Richard Krever, editors) (Kluwer Law International 2014)

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

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

Auer/Seminole Rock Deference in the Tax Court, 11 Pitt. Tax Rev. 1 (2013)

Reforming Federal Tax Litigation: An Agenda, 41 Fla. St. U. L. Rev. 205 (2013)