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Effect of the APA on IRS Guidance
Contains material from Feb 2024
Taxpayers are increasingly challenging the validity of Treasury Regulations and Notices under the Administrative Procedure Act (APA). The IRS has traditionally relied on the Anti-Injunction Act as a barrier to pre-enforcement challenges to its rules and regulations, but courts are now finding APA challenges outside the scope of the Anti-Injunction Act's limitation on judicial review. Hear a discussion of current law on APA challenges to IRS guidance, as well as where the law should move.
Includes: Video Audio Slides
- Total Credit Hours:
- 1.00
- Credit Info
- TX, CA
- TX MCLE credit expires: 2/28/2025
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Effect of the APA on IRS Guidance (Feb 2024)
Kristin E. Hickman, Calvin H. Johnson, Susan C. Morse
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Effect of the APA on IRS Guidance (Feb 2024)
Taxpayers are increasingly challenging the validity of Treasury Regulations and Notices under the Administrative Procedure Act (APA). The IRS has traditionally relied on the Anti-Injunction Act as a barrier to pre-enforcement challenges to its rules and regulations, but courts are now finding APA challenges outside the scope of the Anti-Injunction Act's limitation on judicial review. Hear a discussion of current law on APA challenges to IRS guidance, as well as where the law should move.
Originally presented: Dec 2023 Taxation Conference: Day 2 - Focus on Tax Controversy
Kristin E. Hickman,
University of Minnesota Law School - Minneapolis, MN
Calvin H. Johnson,
The University of Texas School of Law - Austin, TX
Susan C. Morse,
The University of Texas School of Law - Austin, TX