Pages

▼
Showing posts with label 28 USC 2401(a). Show all posts
Showing posts with label 28 USC 2401(a). Show all posts
Sunday, December 8, 2024

Guest Blog: Professors McGovern and Brewer on Developments in Hewitt Holding Regulation Procedurally Invalid (12/8/24)

›
This morning I offer a guest blog from Professors Bruce McGovern, teaching tax law at the South Texas College of Law Houston (school resume ...
Wednesday, July 10, 2024

Does Corner Post Permit § 2401(a)’s 6-year Statute of Limitation to Apply from Date of Regulation for Procedural Challenges? (7/10/24; 8/17/24)

›
Added 7/11/24 4:00 pm : Caveat: My blog post below was an attempt to hammer Corner Post into the interpretive system as I understood it. Wi...
Thursday, March 28, 2024

Tax Court Holds Conservation Easement Proceeds Regulation Invalid Consistent with Eleventh Circuit Holding in Hewitt (3/28/24; 4/6/24)

›
In  Valley Park Ranch, LLC v. Commissioner , 162 T.C. ___ No. 6 (3/28/24) (reviewed opinion), JAT Google Docs here  and GS temp link here (...
Thursday, February 22, 2024

Oral Argument in Corner Post on Whether Procedural Challenges to Regulations Are Subject to § 2401(a)’s Six-Year Statute of Limitations (2/21/24; 4/6/24)

›
I previously included in another blog an introduction to Corner Post v. Board of Governors of the Federal Reserve System (Sup. Ct. Case No....
Sunday, October 1, 2023

Update on Supreme Court Deference Case (with Speculation) and New Supreme Court case on General 6-year Statute for Challenging Regulations Interpretations (Without Speculation) (10/1/23)

›
  Loper Bright (22-451) The Supreme Court docket for the October Term includes  Loper Bright Enterprises v. Raimondo (SEC)  (Sup. Ct. Dkt. 2...
Tuesday, August 6, 2019

Pre-Enforcement Litigation of IRS Guidance (8/6/19)

›
I just finished today my 2019 editions (Practitioner and Student) of my Federal Tax Procedure Book.  I have submitted those editions to SSRN...