Before reading this article one might wish first to become familiar with the works of Patricia Cain on the relationship of the tax code and sexual orientation. Rickey takes her observations a step further, finding in the tensions between DOMA, which forbids recognizing same-sex marriages, and the IRC, "which uses marital status to identify parties likely to collude in order to minimize their collective tax burden," a new way to force the hand of anti-marriage supporters. They must either knowingly "allow a 'homosexual-only tax shelter'" or "recognize same-sex relationships for the purpose of tax law." Forcing the government to make this choice results from what the author calls a "gonzo" tax strategy, one that by insisting upon the strict application of the rules leads to their disruption, which can be contrasted with a "guerilla" strategy of collective disobedience of those rules.