65 Am. U. L. Rev. 1195 (2016) *Shackelford Professor of Taxation and Distinguished Research Professor Emeritus, University of Georgia School of Law.  The Author would like to thank Harley Duncan and Jon Sedon for their helpful comments on an earlier draft of this Article.  All remaining errors in the Article are his own. Download PDF…

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65 Am. U. L. Rev. 87 (2015) *Senior Partner, Sanger, Swysen & Dunkle.  Adjunct Professor of Law, Santa Barbara College of Law.  J.D., University of California at Los Angeles; B.A., University of California at Santa Barbara.  Certified Criminal Law Specialist, The State Bar of California Board of Legal Specialization.  Technical portions of this paper topic were…

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