Readers of this blog may be interested in an excellent cross-posting by Professors Susan Morse (Texas) and Stephen Shay on the state of play and their views on Altera. See Pending Cert Petition in Altera: Tax Law in an Administrative Law Wrapper (Procedurally Taxing Blog 5/22/20), here and Pending cert petition in Altera: tax law in an administrative law wrapper, by Susan C. Morse and Stephen E. Shay (Notice & Comment 5/22/20), here. I highly recommend the offerings (reading either of them is obviously sufficient). The authors contributed to an amicus brief opposing certiorari, so they summarize their view of the case.
JAT Comments:
1. The petition for cert and the S.G.’s brief in opp may be viewed, along with amicus briefs, at the SCOTUSblog site here. Altera's reply, if any, has not been filed yet.
2. I posted a comment on the Procedurally Taxing Blog posting. My comment, beside saying that the posting was excellent, was in the form of questions on perhaps side issues that piqued my interest after reading the offering. Readers can see my comments here.
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