Drennan: Strict Liability and Tax Penalties

William A. Drennan (Southern Illinois) has published Strict Liability and Tax Penalties, 62 Okla. L. Rev. 1 (2009). Here is the abstract:

Taxpayers who fail to pay their fair share cause each honest taxpayer to pay over $2,000 extra in federal income taxes every year. This Article asserts that the current monetary penalty system fails to curb tax dodging because it is a fault-based, negligence style system, and any fault-based system would fail because of systemic features of our federal income tax. This Article proposes a new strict liability style penalty system, tempered by a graduated penalty rate and an exception for any nonfrivolous tax position conspicuoulsy disclosed.