FTPB 2020 Update 01 - Reliance Regulations (Category of Proposed Regulations) (8/8/20)

I provide Federal Tax Procedure book update to the discussion on proposed regulations to add the category of reliance regulations.  The update is here.  (The cumulative list of updates is on the page linked in the right column titled Federal Tax Procedure Book Updates, here.)  In brief, although taxpayers may generally not rely on proposed regulations, they may rely if:  (i) there are no applicable final or temporary regulations and (ii) the IRS so states in the preamble to the proposed regulation.  In addition, IRS attorneys should should generally take positions consistent with proposed regulations.