I am a lawyer and scholar of federal taxation. I currently serve as an Assistant Professor at Emory Law School, where I teach Federal Income Taxation, Partnership Tax, Corporate Tax, as well as seminars about tax policy, political theory, and legal history. Before coming to Emory, I clerked for the Hon. William A. Fletcher on the United States Court of Appeals for the Ninth Circuit, and for the Hon. Guido Calabresi on the United States Court of Appeals for the Second Circuit. I received my J.D. from Yale Law School, where I served as Managing Editor of the Yale Law Journal and won the Clifford L. Porter Prize in Taxation. I earned a Ph.D. in Classics and Philosophy from Yale University.
I have written fairly consistently about how taxation structures the fiscal relationship between (individual or institutional) citizens and the democratic state. My recent works explore (1) how fiscal citizenship in an egalitarian society heightens the need for transparency of income-tax records (“Fiscal Citizenship and Taxpayer Privacy,” Columbia Law Review); (2) how evolving federal revenue streams have created distinctive tax status for U.S. territories like Puerto Rico (“The Origins of U.S. Territorial Taxation,” Yale Law Journal Forum); (3) Congress’s power to tax unrealized gains or wealth under the doctrinal framework interpreting the Sixteenth Amendment (“Rethinking Eisner v. Macomber,” George Washington Law Review); and (4) how IRS under-enforcement has allowed tax law to subsidize discrimination (“Antidiscrimination and Tax Exemption,” Cornell Law Review). Works in progress examine the role of procedure and distributive discourse in shaping tax policy, as well as the taxing powers of U.S. territories and Native tribes. My scholarship aims to strengthen the discursive, institutional, and constitutional infrastructure that will foster tax-policy outcomes which better cohere with democracy and egalitarianism.
I have an additional interest in using classical (i.e., ancient Greek and Roman) political theory and practices to illuminate today’s debate in doctrine and policy. Recent works include “Separation of Structures” (Virginia Law Review), as well as two forum essays from NYU Law Review and Stanford Law Review (“Ostracism and Democracy” and “Damnatio Memoriae and Black Lives Matter,” respectively).
My work has been cited by the U.S. Supreme Court in Moore v. United States, 602 U.S. __ (2024), a key case about the federal taxing power.