Federal Tax Procedure

Jack Townsend offers this blog in conjunction with his Federal Tax Procedure Books, currently in the 2019 editions (Student and Practitioner). Annual editions of the books are published in August. Those books may be downloaded from SSRN (see the page link in the top right hand column of this blog title 2019 Federal Tax Procedure Book & Updates). In addition, Jack uses this blog to discuss issues of federal tax procedure.

About Me

Jack Townsend

View my complete profile

Federal Tax Procedure

Pages

SSRN Paper: Loper Bright Is the Law But Poor Statutory Interpretation (10/28/24; 1/20/25)

First Circuit Holds that JDS for Crypto Records Is Not Entitled to Pre-Enforcement Review (10/1/24)

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)

District Court Rejects State End-Run of Federal Tax SALT Limitations with State Creditable "Charitable" Contribution (4/8/24)

Article on The Tax Contribution to Deference and APA § 706 Posted on SSRN (12/14/23)

Fun Word Distractions While Researching the APA (7/24/23)

On Remand from 6th Circuit, District Court Orders Vacatur of Listed Transaction Notice (1/19/23)

Fifth Circuit En Banc Reverses the Bump Stock Regulation By Wobbling Around Statutory Interpretation Issues (Including Chevron) (1/8/23)

Law Prof Article on the APA Tax Revolution and My Extended Comments (12/1/22; 12/3/22)

District Court Holds IRS Tax Shelter Notice Imposing Obligations Invalid as a Legislative Rule Without Notice-and-Comment But Limits Holding to Parties (11/20/22)

Tax Court in Reviewed Opinion Invalidates Notice Identifying Reportable Transactions (11/10/22)

First Circuit Holds that Target of JDS May Bring Challenge to JDS Prior to Tax Enforcement Against Target (11/9/22)

Reply to Professor Hickman's Response to My PT Article (6/17/22; 6/24/22)

Guest Post on Procedurally Taxing Blog and Jack Cummings' on the APA Legislative-Interpretive Distinction (6/15/22; 6/16/22)

On The Further Weaponization of the APA and Chevron Deference (4/19/22)

Court Invalidates Regulation for Invalidity of Good Cause Statement (4/6/22)

IRS Enjoined from Enforcing Tax Shelter Notice Requirement for Material Advisor for Microcaptive Transactions (9/22/21)

Draft Article on Interpretive Regulations and Chevron Deference (8/31/21)

Does Treasury Comply with Administrative Law, Including the APA? I Say Yes. Others Say No. (7/17/21)

Supreme Court Holds in CIC Services that IRS Micro-Captive Notice May Be Contested Pre-Enforcement (5/17/21; 5/18/21)