The King is Dead Long Live the King!
The Curious Case of Nonappropriated Fund Instrumentalities

The above is the title of an article which appeared in the February, 2006 edition of the Connecticut Law Review.  Written by Evan C. Zoldan, a former law clerk for two of the former judges of the U.S. Court of Federal Claims, it is perhaps the most thorough and complete review of the history and background of the Non-Appropriated Funds doctrine that has been written and it makes a very compelling argument that the so-called 'doctrine' has been erroneous from the very beginning.  As it is copyrighted, we cannot make it available here, but we can provide a link to where it can be found: