Document Type
Article
Publication Date
2024
Publication
Florida State University Law Review
Volume
51
Abbreviation
Fla. St. U. L. Rev.
First Page
597
Abstract
Congress last reformed the nation’s current tax penalty regime ap-proximately three decades ago, long before the rise of big data and the advent of predictive analytics. With predictive analytics now gaining preeminence and its accuracy constantly improving, it is time for Congress to weave this technological innovation into the fabric of the Internal Revenue Code and, more specifically, the civil tax penalty regime. Doing so would enhance taxpayer compliance, augment transparency, and simultaneously ease many administrative burdens commonplace under the tax law.