Virginia v. Sebelius
Douglas Laycock
dlaycock at virginia.edu
Wed Dec 15 14:31:28 PST 2010
Unless they've recently amended the Tax Lien Act (§6321 et seq.) in a way that would be inconsistent with four centuries of law on secret liens, the property in Ilya's hypothetical would pass free of the lien, and the lien would attach to the proceeds in the seller's hands.
On Wed, 15 Dec 2010 17:28:17 -0500
Ilya Somin <isomin at gmu.edu> wrote:
>It's a good point, and I don't disagree with it. It is not my view that the Section 6321 lien available to the government under the mandate penalty trumps all other liens or will always be effective. I merely sought to argue that the penalty can be enforced by means other than reductions in a tax refund.
>
>The interesting question is: What if the person in question failed to pay the mandate penalty at Time A, a Section 6321 lien is created at Time B, but then he or she sells some of the property subject to the lien at Time C (after the lien already exists). I would assume that either the lien would follow the property or the sale would be disallowed. But I am not sure.
>
>
>Ilya Somin
>Associate Professor of Law
>Editor, Supreme Court Economic Review
>George Mason University School of Law
>3301 Fairfax Dr.
>Arlington, VA 22201
>ph: 703-993-8069
>fax: 703-993-8124
>e-mail: isomin at gmu.edu
>Website: http://mason.gmu.edu/~isomin/
>SSRN Page: http://ssrn.com/author=333339
>
>
>----- Original Message -----
>From: Douglas Laycock <dlaycock at virginia.edu>
>Date: Wednesday, December 15, 2010 5:09 pm
>Subject: Re: Virginia v. Sebelius
>
>> I haven't read the Act or the report. But I did used to teach
>> Secured Credit.
>>
>> Normally, an unfiled lien is enforceable against the debtor, but
>> not against any third party who acquires an interest in the
>> debtor's property without notice of the lien.
>>
>> So unless there is some more specific provision that modifies the
>> usual rules, the IRS could enforce these unfiled liens by seizing
>> prpoerty -- but only at the risk of having to turn the property
>> over, or perhaps of monetary liability if the property had been
>> disposed of, to third parties who had acquired liens of their own
>> in the same property. I have no idea whether there is a waiver of
>> sovereign immunity that would apply to such claims.
>>
>> On Wed, 15 Dec 2010 15:21:34 -0500
>> Kermit Roosevelt <krooseve at law.upenn.edu> wrote:
>> >I'm going to stop after this, because I don't think the
>> enforcement measures available matter that much to the "is it a
>> tax" question, since of course ordinary taxes can be enforced by
>> levies etc. But ...
>> >
>> >If you had read the CRS report carefully, you would have seen
>> that it did not say the penalty could be enforced by levies, which
>> you asserted.
>> >If you had read the text of the individual mandate provision, you
>> would have seen that any such claim would be clearly inconsistent
>> with the statutory language anyway.
>> >If you had read the text of the statute you would also have seen
>> that it prohibits the filing of a notice of lien, which is
>> required for the IRS to "go after ALL of the property," as you
>> asserted.>What is the effect of a statutory lien without a filing
>> of notice? We know already that the IRS can't levy and seize the
>> property. If you read IRC 6323, you will see that a silent lien
>> is junior to several other listed liens and also to the rights of
>> a purchaser, so you can hold your property or sell it without
>> consequence. The lien won't go in the public records. I don't see
>> any practical consequence. (I find the CRS treatment of this
>> issue a little disingenuous and in some tension with 6323--why do
>> they say it's superior to "most" liens? How is the IRS supposed to
>> "present its claim" at a private sale and get the proceeds?--which
>> makes me question their non-partisanship, but as I said I'm not an
>> expert on IRS enforcement.)
>> >
>> >Of course all of our participation in this listserv is a little
>> off the cuff, as you put it, and we all have lots of other things
>> that we're doing and don't necessarily read or investigate
>> everything we talk about prior to posting. Certainly I don't.
>> But then again, it's not the case that one of the other things I'm
>> doing is writing an amicus brief about the constitutionality of
>> this particular provision.
>> >
>> >Kermit Roosevelt
>> >Professor of Law
>> >University of Pennsylvania Law School
>> >3400 Chestnut St.
>> >Philadelphia PA 19104
>> >215.746.8775
>> >-----Original Message-----
>> >From: Ilya Somin [mailto:isomin at gmu.edu]
>> >Sent: Wednesday, December 15, 2010 2:48 PM
>> >To: Kermit Roosevelt
>> >Cc: John Bickers; CONLAWPROFS professors
>> >Subject: Re: Virginia v. Sebelius
>> >
>> >The commissioner of the IRS said nothing about the Section 6321
>> silent lien (which is a standard tax collection tool), and in any
>> event was speaking off the cuff in an interview. He did not
>> categorically rule out the use of all liens.
>> >
>> >As for the CRS report, they fairly clearly laid out which
>> enforcement powers are available under the act and which are not.
>> The silent lien falls under the former category pretty clearly.
>> >
>> >Ilya Somin
>> >Associate Professor of Law
>> >Editor, Supreme Court Economic Review
>> >George Mason University School of Law
>> >3301 Fairfax Dr.
>> >Arlington, VA 22201
>> >ph: 703-993-8069
>> >fax: 703-993-8124
>> >e-mail: isomin at gmu.edu
>> >Website: http://mason.gmu.edu/~isomin/
>> >SSRN Page: http://ssrn.com/author=333339
>> >
>> >
>> >----- Original Message -----
>> >From: Kermit Roosevelt <krooseve at law.upenn.edu>
>> >Date: Wednesday, December 15, 2010 9:51 am
>> >Subject: Re: Virginia v. Sebelius
>> >
>> >> Well, I'm not an expert on IRS enforcement procedures, but I think
>> >> the effect of a lien might be limited if they can't notice it. The
>> >> Commissioner of the IRS seemed to think so, anyway, in the
>> >> discussion I linked to. As for the CRS report, I don't know if
>> >> Coburn has particular go-to people or what, but they didn't say
>> >> much about the prohibition on filing a notice of lien and they
>> >> spent enough time discussing the scary general collection powers
>> >> of the IRS to mislead even sophisticated legal minds into thinking
>> >> those powers were available to enforce the penalty.
>> >> Here's the link again.
>> >> http://www.slate.com/id/2250098
>> >> Kermit Roosevelt
>> >> Professor of Law
>> >> University of Pennsylvania Law School
>> >> 3400 Chestnut St.
>> >> Philadelphia PA 19104
>> >> 215.746.8775
>> >>
>> >> On Dec 14, 2010, at 10:50 PM, "Ilya Somin" <isomin at gmu.edu> wrote:
>> >>
>> >> > The statutory language forbids "fil[ing] notice of lien," but
>> >> not liens themselves. As the CRS report notes (pg. 5), a Section
>> >> 6321 statutory lien does not require filing of a notice of lien.
>> >> >
>> >> > It is true that the CRS report was requested by Coburn, who may
>> >> have had partisan reasons for doing so. But the authors of the
>> >> report are not his personal employees, and they don't appear to
>> >> have minsinterpreted the statutory language. As I understand the
>> >> CRS' operating procedures, they are supposed to answer the
>> >> questions members of Congress pose, but are not constrained in the
>> >> substance of the answers they can give, and cannot be punished or
>> >> fired for giving answers the member doesn't like.
>> >> >
>> >> > Ilya Somin
>> >> > Associate Professor of Law
>> >> > Editor, Supreme Court Economic Review
>> >> > George Mason University School of Law
>> >> > 3301 Fairfax Dr.
>> >> > Arlington, VA 22201
>> >> > ph: 703-993-8069
>> >> > fax: 703-993-8124
>> >> > e-mail: isomin at gmu.edu
>> >> > Website: http://mason.gmu.edu/~isomin/
>> >> > SSRN Page: http://ssrn.com/author=333339
>> >> >
>> >> >
>> >> > ----- Original Message -----
>> >> > From: Kermit Roosevelt <krooseve at law.upenn.edu>
>> >> > Date: Tuesday, December 14, 2010 10:31 pm
>> >> > Subject: Re: Virginia v. Sebelius
>> >> >
>> >> >> I hate to quibble with coburn's CSR people, but I did remember
>> >> >> people saying it was only enforceable through refund deductions,
>> >> >> so I did a little looking on the Internet (only on my phone
>> since>> >> that's what I have) and the statutory language I find
>> prohibits>> >> liens as well as levies. It's linked from this
>> discussion on Slate
>> >> >> which also has the IRS commissioner saying that refund deduction
>> >> >> is the only enforcement method.
>> >> >> http://www.slate.com/id/2250098
>> >> >> So unless you have some statutory language or IRS ruling, I'm
>> >> >> standing by the initial assertion.
>> >> >>
>> >> >> Kermit Roosevelt
>> >> >> Professor of Law
>> >> >> University of Pennsylvania Law School
>> >> >> 3400 Chestnut St.
>> >> >> Philadelphia PA 19104
>> >> >> 215.746.8775
>> >> >>
>> >> >> On Dec 14, 2010, at 10:10 PM, "Ilya Somin" <isomin at gmu.edu>
>> wrote:>> >>
>> >> >>> That section (pg. 7) states that the IRS may impose a levy on
>> >> >> property based on a Notice of Federal Tax Lien (NFTL).
>> However, it
>> >> >> then goes on to say that "There is no prohibition, however, on
>> >> >> establishing a statutory lien against the taxpayer's
>> >> >>> property under § 6321 [of the Internal Revenue Code]." Section
>> >> >> 6321 allows a "lien in favor of the United States upon ALL
>> >> >> property and rights to property, whether real or personal,
>> >> >>> belonging to such person [who has not paid the relevant
>> fine or
>> >> >> tax]." (emphasis mine).
>> >> >>>
>> >> >>> Furthermore, the IRS also has broad authority to impose late
>> >> >> payment penalties and interest on anyone who fails to comply.
>> >> >>>
>> >> >>> In sum, therefore, PPACA allows the IRS to go after ALL of the
>> >> >> property of a person who fails to pay the fine imposed by the
>> >> >> mandate, and also gives them the power to impose various late
>> >> >> payment and interest fees.
>> >> >>>
>> >> >>> It is therefore clear that Kermit's initial claim that the
>> fine>> >> "can only be collected from an unwilling payer by
>> deduction from
>> >> >> an income
>> >> >>> tax refund" was incorrect. Rather, the fine is enforced
>> much the
>> >> >> same way as most other civil fines are: through liens on
>> property>> >> and additional fines for late payment or noncompliance.
>> >> >>>
>> >> >>> Ilya Somin
>> >> >>> Associate Professor of Law
>> >> >>> Editor, Supreme Court Economic Review
>> >> >>> George Mason University School of Law
>> >> >>> 3301 Fairfax Dr.
>> >> >>> Arlington, VA 22201
>> >> >>> ph: 703-993-8069
>> >> >>> fax: 703-993-8124
>> >> >>> e-mail: isomin at gmu.edu
>> >> >>> Website: http://mason.gmu.edu/~isomin/
>> >> >>> SSRN Page: http://ssrn.com/author=333339
>> >> >>>
>> >> >>>
>> >> >>> ----- Original Message -----
>> >> >>> From: Kermit Roosevelt <krooseve at law.upenn.edu>
>> >> >>> Date: Tuesday, December 14, 2010 9:57 pm
>> >> >>> Subject: Re: Virginia v. Sebelius
>> >> >>>
>> >> >>>> Yes, that's from the section about general IRS collection
>> >> >>>> procedures on page 6. Then there's a section about
>> collection of
>> >> >>>> the penalty, page 7, which says the means of collection are
>> >> >>>> limited and, in particular, and directly contrary to the
>> language>> >>>> you quoted, the IRS may not levy any property. Do
>> you happen to
>> >> >>>> know if the claim that the IRS will take your real and
>> personal>> >>>> property if you don't buy health insurance is a
>> common one in
>> >> this>>>> debate? I would really like to see it corrected if it is.
>> >> >>>>
>> >> >>>> Kermit Roosevelt
>> >> >>>> Professor of Law
>> >> >>>> University of Pennsylvania Law School
>> >> >>>> 3400 Chestnut St.
>> >> >>>> Philadelphia PA 19104
>> >> >>>> 215.746.8775
>> >> >>>>
>> >> >>>> On Dec 14, 2010, at 9:02 PM, "Ilya Somin" <isomin at gmu.edu>
>> wrote:>> >>>>
>> >> >>>>> I did read the report. According to the CRS, the means of
>> >> >>>> collection include the following:
>> >> >>>>>
>> >> >>>>> "Thirty days after providing a Final Notice of Intent to Levy
>> >> >>>> and Notice of Your Right to Appeal, the IRS may levy the
>> >> >>>> taxpayer's property, both real and personal. This means that
>> >> wages>>>> may be garnished until the tax is paid in full. All
>> >> funds in a
>> >> >>>> bank account that are available for withdrawal on the date the
>> >> >>>> levy is received by the bank may be taken. In some cases,
>> the IRS
>> >> >>>> may sell property belonging to the taxpayer after providing
>> >> public>>>> notice and advising the taxpayer of the minimum bid
>> price.">> >> (pg. 6)
>> >> >>>>>
>> >> >>>>> The IRS is also allowed to levy interest and additional
>> >> >>>> penalties for late payment of the initial penalty.
>> >> >>>>>
>> >> >>>>> This paragraph occurs in a section of the report entitled
>> >> >>>> "collection." It is true, as I noted in my last post, that
>> there>> >>>> is no criminal penalty for noncompliance. But there
>> is a wide
>> >> >>>> range of civil penalties and collection mechanisms that go far
>> >> >>>> beyond reductions in tax deductions.
>> >> >>>>>
>> >> >>>>> Obviously, the means of enforcement are not completely
>> >> >>>> unlimited. But that, of course, is true for any penalty, even
>> >> >>>> those that do have criminal liability.
>> >> >>>>>
>> >> >>>>> Ilya Somin
>> >> >>>>> Associate Professor of Law
>> >> >>>>> Editor, Supreme Court Economic Review
>> >> >>>>> George Mason University School of Law
>> >> >>>>> 3301 Fairfax Dr.
>> >> >>>>> Arlington, VA 22201
>> >> >>>>> ph: 703-993-8069
>> >> >>>>> fax: 703-993-8124
>> >> >>>>> e-mail: isomin at gmu.edu
>> >> >>>>> Website: http://mason.gmu.edu/~isomin/
>> >> >>>>> SSRN Page: http://ssrn.com/author=333339
>> >> >>>>>
>> >> >>>>>
>> >> >>>>> ----- Original Message -----
>> >> >>>>> From: Kermit Roosevelt <krooseve at law.upenn.edu>
>> >> >>>>> Date: Tuesday, December 14, 2010 8:56 pm
>> >> >>>>> Subject: Re: Virginia v. Sebelius
>> >> >>>>>
>> >> >>>>>> Assessment is not the same as collection. If you read the
>> >> >>>> report
>> >> >>>>>> you will see that means of collection are limited. I
>> hope your
>> >> >>>>>> misconception is not widespread, because it would seriously
>> >> >>>>>> distort public discussion of this.
>> >> >>>>>>
>> >> >>>>>> Kermit Roosevelt
>> >> >>>>>> Professor of Law
>> >> >>>>>> University of Pennsylvania Law School
>> >> >>>>>> 3400 Chestnut St.
>> >> >>>>>> Philadelphia PA 19104
>> >> >>>>>> 215.746.8775
>> >> >>>>>>
>> >> >>>>>> On Dec 14, 2010, at 8:46 PM, "Ilya Somin" <isomin at gmu.edu>
>> >> wrote:>>>>>>
>> >> >>>>>>> This is a distinction without a difference. Whether a
>> monetary>> >>>>>> fine is a tax or a penalty surely can't turn on
>> what government
>> >> >>>>>> agency happens to collect the fine.
>> >> >>>>>>>
>> >> >>>>>>> Moreover, the enforcement provision is not in fact
>> limited to
>> >> >>>>>> reduction of income tax deductions. As a Congressional
>> >> >>>> Research
>> >> >>>>>> service report points out, "Nothing in PPACA limits the
>> IRS's>> >>>>>> authority or means for assessing the penalty." The
>> report goes
>> >> >>>> on
>> >> >>>>>> to explain that the IRS could collect the penalty through
>> >> >>>> levies
>> >> >>>>>> on the offender's property, "both real and personal."
>> >> >>>>>>>
>> >> >>>>>>> See here for the report:
>> >> >>>>>>>
>> >> >>>>>>>
>> >> >>>>>>
>> >> >>>>
>> >> >>
>> >>
>> http://coburn.senate.gov/public/index.cfm?a=Files.Serve&File_id=2ec1e180-afbf-4a48-ba12-8dea812ac30a
>> >> >>>>>>>
>> >> >>>>>>>
>> >> >>>>>>> Ilya Somin
>> >> >>>>>>> Associate Professor of Law
>> >> >>>>>>> Editor, Supreme Court Economic Review
>> >> >>>>>>> George Mason University School of Law
>> >> >>>>>>> 3301 Fairfax Dr.
>> >> >>>>>>> Arlington, VA 22201
>> >> >>>>>>> ph: 703-993-8069
>> >> >>>>>>> fax: 703-993-8124
>> >> >>>>>>> e-mail: isomin at gmu.edu
>> >> >>>>>>> Website: http://mason.gmu.edu/~isomin/
>> >> >>>>>>> SSRN Page: http://ssrn.com/author=333339
>> >> >>>>>>>
>> >> >>>>>>>
>> >> >>>>>>> ----- Original Message -----
>> >> >>>>>>> From: John Bickers <bickersj1 at nku.edu>
>> >> >>>>>>> Date: Tuesday, December 14, 2010 8:23 pm
>> >> >>>>>>> Subject: RE: RE: RE: Virginia v. Sebelius
>> >> >>>>>>>
>> >> >>>>>>>> "As things stand, the claim that this is a tax rests
>> solely>> >>>> on
>> >> >>>>>> the
>> >> >>>>>>>> basis that it imposes a monetary fine for noncompliance."
>> >> >>>>>>>>
>> >> >>>>>>>> No, not solely. It is placed in the internal revenue
>> code;>> >>>> it
>> >> >>>>>> is
>> >> >>>>>>>> administered by the internal revenue service; it can
>> only be
>> >> >>>>>>>> collected from an unwilling payer by deduction from an
>> income>> >>>>>> tax
>> >> >>>>>>>> refund.
>> >> >>>>>>>> Fines, it seems to me, are assessed by courts, or at
>> >> least by
>> >> >>>>>>>> administrative quasi-judicial agencies. This is
>> assessed by
>> >> >>>>>> the
>> >> >>>>>>>> IRS, on their own, automatically, if the taxpayer
>> doesn't a)
>> >> >>>>>> show
>> >> >>>>>>>> that they have qualifying insurance, b) claim a religious
>> >> >>>>>>>> exception, or c) pay little or no income tax (as you
>> note).>> >>>> If
>> >> >>>>>> my
>> >> >>>>>>>> child suddenly received a full scholarship at college, my
>> >> >>>> taxes
>> >> >>>>>>>> would go up, automatically, and without any court
>> >> >>>> proceedings.
>> >> >>>>>> I
>> >> >>>>>>>> don't believe that is a fine, and I don't see the
>> PPACA as
>> >> >>>> any
>> >> >>>>>>>> different.
>> >> >>>>>>>> Had Congress passed the law frequently described in the
>> >> >> press-
>> >> >>>> -
>> >> >>>>>> in
>> >> >>>>>>>> which we are compelled to buy insurance or find ourselves
>> >> >>>> being
>> >> >>>>>>>> declared outlaw and subject to the full weight of federal
>> >> >>>> power-
>> >> >>>>>> -I
>> >> >>>>>>>> could understand your position. In the law they actually
>> >> >>>>>> passed,
>> >> >>>>>>>> I wonder not about authority, but about efficacy: it
>> >> seems to
>> >> >>>>>> me
>> >> >>>>>>>> still worth my while, if I were a young, (over-) confident
>> >> >>>>>> person,
>> >> >>>>>>>> to simply ignore this "compulsion" and pay the extra seven
>> >> >>>>>> hundred
>> >> >>>>>>>> dollars.
>> >> >>>>>>>>
>> >> >>>>>>>> John Bickers
>> >> >>>>>>>> Salmon P. Chase College of Law
>> >> >>>>>>>> Northern Kentucky University
>> >> >>>>>>>>
>> >> >>>>>>>>
>> >> >>>>>>>> -----Original Message-----
>> >> >>>>>>>> From: Ilya Somin [mailto:isomin at gmu.edu]
>> >> >>>>>>>> Sent: Tue 12/14/2010 7:24 PM
>> >> >>>>>>>> To: John Bickers
>> >> >>>>>>>> Cc: Malla Pollack; CONLAWPROFS professors
>> >> >>>>>>>> Subject: Re: RE: RE: Virginia v. Sebelius
>> >> >>>>>>>>
>> >> >>>>>>>> Absolutely they could. If there was a deduction from a
>> >> >>>>>> preexisting
>> >> >>>>>>>> tax that is otherwise permitted by the Constitution,
>> such as
>> >> >>>>>> the
>> >> >>>>>>>> income tax or an excise tax. But this law does not do any
>> >> >>>> such
>> >> >>>>>>>> thing. It imposes a free-standing regulatory penalty
>> that is
>> >> >>>>>> not a
>> >> >>>>>>>> deduction from any other tax.
>> >> >>>>>>>>
>> >> >>>>>>>> If Congress had structured this as an income tax
>> deduction,>> >>>> it
>> >> >>>>>>>> would have given little or no incentive to the many people
>> >> >>>> who
>> >> >>>>>> pay
>> >> >>>>>>>> little or no income tax.
>> >> >>>>>>>>
>> >> >>>>>>>> Alternatively, congress could have simply raised
>> income taxes
>> >> >>>>>> on
>> >> >>>>>>>> everyone and then offered a deduction to those who
>> purchase>> >>>>>> health
>> >> >>>>>>>> insurance. But that would have required admitting that the
>> >> >>>> law
>> >> >>>>>>>> increases taxes (something that the president and
>> >> >>>> congressional
>> >> >>>>>>>> leaders repeatedly denied), and would therefore have been
>> >> >>>>>>>> politically infeasible.
>> >> >>>>>>>>
>> >> >>>>>>>> As things stand, the claim that this is a tax rests
>> >> solely on
>> >> >>>>>> the
>> >> >>>>>>>> basis that it imposes a monetary fine for
>> noncompliance. By
>> >> >>>>>> that
>> >> >>>>>>>> standard, any fine for violation of any law counts as
>> a tax.
>> >> >>>> If
>> >> >>>>>>>> people are fined for not exercising every day, not
>> buying a
>> >> >>>> GM
>> >> >>>>>>>> car, etc., that would be a tax too. This goes against both
>> >> >>>>>> Supreme
>> >> >>>>>>>> Court precedent (which repeatedly distinguishes
>> between taxes
>> >> >>>>>> and
>> >> >>>>>>>> regulatory penalties, most recently in a 1996 decision
>> >> >>>> written
>> >> >>>>>> by
>> >> >>>>>>>> that evil reactionary Justice Souter), and also common
>> sense.>> >>>>>>>>
>> >> >>>>>>>> Ilya Somin
>> >> >>>>>>>> Associate Professor of Law
>> >> >>>>>>>> Editor, Supreme Court Economic Review
>> >> >>>>>>>> George Mason University School of Law
>> >> >>>>>>>> 3301 Fairfax Dr.
>> >> >>>>>>>> Arlington, VA 22201
>> >> >>>>>>>> ph: 703-993-8069
>> >> >>>>>>>> fax: 703-993-8124
>> >> >>>>>>>> e-mail: isomin at gmu.edu
>> >> >>>>>>>> Website: http://mason.gmu.edu/~isomin/
>> >> >>>>>>>> SSRN Page: http://ssrn.com/author=333339
>> >> >>>>>>>>
>> >> >>>>>>>>
>> >> >>>>>>>>
>> >> >>>>>>> _______________________________________________
>> >> >>>>>>> To post, send message to Conlawprof at lists.ucla.edu
>> >> >>>>>>> To subscribe, unsubscribe, change options, or get password,
>> >> >>>> see
>> >> >>>>>> http://lists.ucla.edu/cgi-bin/mailman/listinfo/conlawprof
>> >> >>>>>>>
>> >> >>>>>>> Please note that messages sent to this large list
>> cannot be
>> >> >>>>>> viewed as private. Anyone can subscribe to the list and
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>> >> >>>>>> list members can (rightly or wrongly) forward the
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>> >> >>>> others.>>
>> >> >>>>
>> >> >>
>> >>
>> >_______________________________________________
>> >To post, send message to Conlawprof at lists.ucla.edu
>> >To subscribe, unsubscribe, change options, or get password, see
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>> >Please note that messages sent to this large list cannot be
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>>
>> Douglas Laycock
>> Armistead M. Dobie Professor of Law
>> University of Virginia Law School
>> 580 Massie Road
>> Charlottesville, VA 22903
>> 434-243-8546
>>
Douglas Laycock
Armistead M. Dobie Professor of Law
University of Virginia Law School
580 Massie Road
Charlottesville, VA 22903
434-243-8546
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