I have posted to SSRN a major update of my prior article titled The Report of the Death of the Interpretive Regulation Is an Exaggeration. The update is dated December 14, 2021. The Abstract summarizing the scope of the article is here. The Abstract offers links to view or download the article.
This will be the last update for this article. (There was one update before this.) If there is something new that I feel appropriate to discuss in an article on SSRN, I will write a new article.
CAVEAT: The Abstract has two problems that I do not know how to fix:
1. As of this morning, the Abstract has a concluding paragraph that I cannot delete for some reason. That concluding paragraph is carried over from the last update and does not apply to this update. I have posted a revision for the Abstract that, when approved, will caution that, if there is text below that point, it is a vestige and readers should ignore that concluding paragraph. The following is the concluding paragraph that readers should ignore:
Note: The principal revisions in the draft linked here are discussions of Supreme Court cases in June 2019. I did make some other minor corrections as well. This "final draft" of the article replaces one originally posted June 6, 2019. I have made substantial revisions to the earlier draft. I do not have plans for further revisions, although I will likely make substantial revisions on this subject to the more summary presentation in my Federal Tax Procedure books (Practitioner and Student Editions) posted on SSRN.
2. The SSRN suggested citation for the article states my author name twice as if there were joint authors of the publication. As it appears now, the suggested citation is:
Townsend, John A. and Townsend, John A., The Report of the Death of the Interpretive Regulation Is an Exaggeration (December 14, 2021). Available at SSRN: https://ssrn.com/abstract=3400489 or http://dx.doi.org/10.2139/ssrn.3400489
The corrected citation in SSRN suggested format should be:
Townsend, John A., The Report of the Death of the Interpretive Regulation Is an Exaggeration (December 14, 2021). Available at SSRN: https://ssrn.com/abstract=3400489 or http://dx.doi.org/10.2139/ssrn.3400489
Actually, the citation that I prefer uses the current convention of identifying the author with first name first:
John A. Townsend. The Report of the Death of the Interpretive Regulation Is an Exaggeration (SSRN December 14, 2021), https://ssrn.com/abstract=3400489
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