Many statutes are administered by administrative agencies. This paper shows that, when interpreting an ambiguous statute, administrative agencies choose between two strategies of statutory interpretation: the risky strategy - a relatively aggressive interpretation that provokes an appeal by the...

Advance tax rulings allow taxpayers to achieve certainty about the tax consequences of contemplated transactions, and are thus considered indispensable in the modern world of tax administration and compliance. After providing empirical evidence of tax law uncertainty, which should give rise to a...

In many contexts, U.S. tax law grants a favorable tax treatment to transactions of one type and an adverse treatment to transactions of another type. The task of tax authorities is to draw lines in legally gray areas, distinguishing between economically similar transactions that should receive...

Across areas of law administrative agencies employ four basic policymaking strategies: rulemaking, adjudication, advance ruling and licensing. How should administrative agencies choose among these policymaking strategies? I develop a model which captures the idea that rules are inherently...

Many statutes are administered by administrative agencies. This paper shows that, when interpreting an ambiguous statute, administrative agencies choose between two strategies of statutory interpretation: the risky strategy, a relatively aggressive interpretation that provokes an appeal by the...

A large literature in law and economics analyzes the phenomenon of crime displacement and its implications for criminal law. Yet a similar phenomenon of harm displacement in the tort context has been ignored by scholars. We develop a simple model of bilateral accidents which allows for harm to...