Article:
Miriam Galston, Lobbying and the Public Interest: Rethinking the Internal Revenue Code's Treatment of Legislative Activities, 71 TEXAS L. REV. 1269 (1993).
 

Abstract:
The author argues that the regulation of lobbying under the Code is problematic in two key respects. First, the rules create four separate and very different lobbying "regimes," three governing the lobbying activities of exempt organizations and one governing deductions for the cost of lobbying activities engaged in by businesses. The author recommends replacing the current lobbying rules in the Code with a more consistent and uniform system of regulation designed to redress the imbalance fostered by the current statutory and regulatory scheme. Second, although the Code's restrictions on lobbying by exempt organizations and businesses have been the subject of much commentary and controversy, these discussions ordinarily evaluate the lobbying rules solely in terms of tax policy concerns. This Article seeks to remedy this defect by examining the four regimes and their justifications against the background of broader issues of political and legal theory, as well as in light of more traditional tax policy concerns.