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Allen Madison

Allen Madison



School of Law 213

Phone: (605) 658-3519




Allen Madison cultivates understanding in the area of federal tax law and enforcement at the University of South Dakota School of Law. Prior to academia, Professor Madison represented or advised participants on all sides of federal tax disputes—litigating against the IRS, serving in the IRS Chief Counsel Office, and clerking for a United States Tax Court Judge. Through these experiences, Professor Madison has realized the great fortune of living in a country where a taxpayer with a legitimate tax dispute may challenge the government without fear of reprisal. Professor Madison's teaching and research examine the engagement between the government and its people in the context of taxation.

Teaching Interests:

Federal tax law and enforcement.

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.

  • Lombardi, Paul, and Madison, Allen. Blurred Justice. In Entertainment, Publishing and the Arts Handbook, edited by Karen B. Tripp. Thomson Reuters (West), 2020.
  • Madison, Allen. Fundamentals of Federal Tax Procedure and Enforcement, Wolters Kluwer (2019)..
  • Madison, Allen. Teacher's Manual, Fundamentals of Federal Tax Procedure and Enforcement, Wolters Kluwer (2019)..
  • Lombardi, Paul, and Madison, Allen. Blurred Justice, 64. Vol. 38. Loyola of Los Angeles Entertainment Law Review , 2019.
  • Madison, Allen. Sharyn Fisk, The Tax Court's Home, 157 Tax Notes 1249 (2017)..
  • Madison, Allen. The IRS's Tax Determination Authority, 71 Tax Law. 143 (2017)..
  • Madison, Allen. The Legal Framework for Tax Compliance, 70 Tax Law. 497 (2017)..
  • Madison, Allen. The Legal Consequences of Noncompliance with Federal Tax Laws, 70 Tax Law. 367 (2016)..
  • Madison, Allen. The Denial of IRS Access to Its Adversary's Playbook, 60 S.D. L. Rev. 232 (2015)..
  • Madison, Allen. The Taxation of Gratuitous Services Gone Out of Control, 45 U. Mem. L. Rev. 115 (2014)..
  • Madison, Allen. The Futility of Tax Protester Arguments, 36 T. Jefferson L. Rev. 253 (2013)..
  • Madison, Allen. Rationalizing Tax Law by Breaking the Addiction to Economic Substance, 47 Idaho L. Rev. 441 (2011)..
  • Madison, Allen. In-House Basics, in Careers In Tax Law: Perspectives On the Tax Profession an What It Holds For You (John Gamino, Robb A. Longman & Matthew R. Sontag, eds. 2009)..
  • Madison, Allen. Revisiting Access to the Tax Court's Deliberative Process, 103 Tax Notes 749 (2004)..
  • Madison, Allen. Important Developments During the Year: Court Procedure and Practice, 56 Tax Law. 1013 (2003)..
  • Madison, Allen. The Tension Between Textualism and Substance-Over-Form Doctrines in Tax Law, 43 Santa Clara L. Rev. 699 (2003)..
  • Madison, Allen. Important Developments During the Year: Court Procedure and Practice, 55 Tax Law. 1075 (2002)..
  • Madison, Allen. Point & Counterpoint: Disclosure and Private Enforcement, ABA Tax Sec. News Q., Fall 2002, at 15 (with Theodore Sims; contribution titled Point: Don't Publicize Corporate Tax Returns or Privatize Enforcement)..
  • Madison, Allen. Access to the Tax Court's Deliberative Process, 91 Tax Notes 2247 (2001)..
  • 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 Colum. 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 U. Det. Mercy L. Rev. 187 (1997)..

Awards and Honors:

  • Fellow, American College of Tax Counsel, 2014


  • Lombardi, Paul, Madison, Allen. Blurred Justice. Presented at the College Music Society Great Plains Chapter, Waverly, IA. (March 18, 2018)