David Gamage cited in TaxProfBlog, September 26, 2013
Well, the duo of Gamage and Shanske might be the Nate Silver(s) of tax controversy, as the Tenth Circuit held in the Brohl case that the reporting requirements constitute a tax for TIA purposes, and, therefore, the district court should not have reached the question of the constitutionality of the reporting requirements under the Commerce Clause.