It’s a total labyrinth that’ll make no sense.
Pappas ’16 [Andrew; Fall 2016; J.D. Candidate, Valparaiso University Law School, B.A. in Economics from Hillsdale College; Valdosta University Law Review, “Wrestling Antaeus: The Necessity of Appointed Counsel in Civil Tax Disputes,” vol. 51]
Taxpayers facing civil action by the IRS deserve more than an opportunity to get lost in the enigmatic labyrinth of the Internal Revenue Code before having their taxes improperly assessed. Tax enforcement has never been extraordinarily clear on where a civil action ends and criminal prosecution begins, and that problem has persisted to this day in areas such as tax fraud. 264 The Tax Court has likewise faced difficulties in categorization and authority, and by its very operation seems to perpetuate the idea of tax exceptionalism, for better or worse. 265 The Supreme Court has acknowledged some bleed between civil and criminal law in certain circumstances, and has recognized a right to paid counsel in particular civil situations. 266 This Note advocates the recognition of that right in one other situation--one in which the subject matter, parties, and forum all lend themselves to its extension.