I am trying to finish up a major revision to an article I wrote involving the administrative law and Administrative Procedure Act (“APA”) distinction between legislative and interpretive regulations. A significant part of the article deals with Chevron deference.
I am posting one part of the Chevron deference discussion in the article where I break down various interpretive categories with the goal of showing Chevron deference is far less outcome determinative that all the commotion about Chevron would suggest.
That part of the discussion in pdf format is here. I would appreciate any feedback (particularly critical feedback) that might be offered. Please offer your comments directly to me at jack@tjtaxlaw.com. Alternatively, if you think it might be useful for reader comment, post as a comment here.
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