Allen Madison

Allen Madison

Associate Professor


School of Law 201

Phone: (605) 677-5362



Curriculum Vitae


Professor Allen D. Madison teaches tax law, including Federal Income Tax, Business Entities Tax, and Federal Tax Enforcement and Procedure. Professor Madison joined the University of South Dakota law faculty in 2012. Prior to joining USD, Professor Madison held teaching positions at Georgetown University, at University of Wyoming, at University of Idaho, and in the Anglo-American Law Program at the University of Navarra in Pamplona, Spain. Before academia, Professor Madison practiced law with a focus on taxation for ten years. After clerking at the U.S. Tax Court, he represented large manufacturing clients for the tax group of Fenwick & West and later served in the IRS Office of Chief Counsel National Office. He also worked in-house at Dow Chemical as an attorney on tax matters.

Teaching Interests:

Federal taxation.

Research Interests:

Tax history, tax theory, tax policy, tax psychology, statutory interpretation, logic, and tax procedure.


  • LLM, Taxation and Securities Regulation, Georgetown University Law Center, 1998
  • JD, Law, Hofstra University School of Law, 1994
  • MBA, Business, Michigan State University Broad Graduate School of Management, 1992
  • BA, Psychology, Michigan State University College of Social Science, 1989
  • BA, Marketing, Michigan State University Collge of Business, 1989


  • Low Income Taxpayer Clinic, United States Internal Revenue Service. Grant Role: Principal. (2015 - 2015)


Citations listed below are presented in a standardized, modified format for display purposes only. They do not necessarily reflect the preferred style and conventions of the faculty member or discipline.

  • Madison, Allen. The Legal Framework for Tax Compliance. 70 Tax Lawyer 497, 2017.
  • Madison, Allen. The Legal Consequences of Noncompliance with Federal Tax Laws. 70 Tax Lawyer 367, 2016.
  • Madison, Allen. The Denial of IRS Access to its Adversary's Playbook, 27. 60 S. D. L. Rev. 232, 2015.
  • Madison, Allen. The Futility of Tax Protester Arguments. 36 T. Jefferson L. Rev. 253, 2014.
  • Madison, Allen. The Taxation of Gratuitous Services Gone out of "Control". 45 U. Memphis L. Rev. 115, 2014.
  • Madison, Allen. Rationalizing Tax Law by Breaking the Addiction to Economic Substance. 47 Idaho L. Rev. 441, 2011.
  • Madison, Allen. The Tension Between Textualism and Substance-Over-Form Doctrine in Tax Law. 43 Santa Clara L. Rev. 699, 2003.
  • Madison, Allen. An Analysis of the IRS's Voluntary Disclosure Policy. 54 Tax Law. 729, 2001.
  • Madison, Allen. Derivatives Regulation in the Context of the Shingle Theory. 1999 Columbia Bus. L. Rev. 271, 1999.
  • Madison, Allen. The Uncopyrightability of Jokes. 35 San Diego L. Rev. 111, 1998.
  • Madison, Allen. The Context of Employment Discrimination in Japan. 74 Detroit Mercy L. Rev. 187, 1997.
  • Madison, Allen. The IRS's Tax Determination Authority. 71 Tax Lawyer __ (2017).
  • Lombardi, Paul, and Madison, Allen. Blurred Justice, 64. Vol. 38. Loyola of Los Angeles Entertainment Law Review .

Awards and Honors:

  • Fellow, American College of Tax Counsel, 2014