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.

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Jack Townsend

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Federal Tax Procedure

Pages

Loper Bright’s Motivated Mistreatment of Statutory Ambiguity and Best Interpretations (8/28/25)

Second Circuit Applies Loper Bright to Approve a Best Interpretation in Treasury Regulation (8/15/25)

Tax Court Applies Statutory Stare Decisis for Chevron Cases (7/3/25)

A Primer on Judicial Review of Tax Regulations after Loper Bright (6/4/25; 6/6/25)

More on Whether Treasury/IRS Interpretations under § 7805(a) Are Entitled to Loper Bright Deference? (5/29/25; 5/30/25)

Final Paper on SSRN Titled: Loper Bright Is the Law But Poor Statutory Interpretation (2/28/25)

The Relation of the Current DOJ Commotion to Loper Bright (2/15/25)

Agency Interpretations, Bell Curves, and Skidmore ooomph under Loper Bright (2/12/25)

On Remand from Supreme Court on Chevron's Demise, D.C. Circuit Holds that Agency Interpretation is Best Interpretation (1/11/25; 1/12/25)

Do General Authority Congressional Delegations of Authority to Prescribe Regulations to Carry Out the Provisions of the Statute Qualify for Loper Bright Deference? (11/12/24)

Post Loper Bright Approval of Agency Best Interpretations (12/3/24)

What was the State of Deference at the Enactment of the APA? (10/7/24)

9th Circuit 3-Judge Panel Has Three Different Interpretations Illustrating the Stupidity of Loper Bright's Rejection of Deference (9/3/24; 9/7/24)

Has Auer Time Passed? (8/20/24)

Tax Court Applies the Best Interpretation as Required by Loper Bright Rejection of Chevron Deference (8/27/24)

Fourth Circuit Applies Auer/Kisor Deference to Include in Guidelines "Loss" the Commentary Inclusion of "Intended Loss" (8/24/24)

Federal Tax Crimes Blog Posting on Interface of Sentencing Guidelines and Loper Bright Interpretive Regime (8/7/24)

More Nuance On Loper Bright's Adoption of the Notion that Courts Say What the Law Is (8/6/24)

Bills to Approve Deference - Stop Corporate Capture Act (7/26/24)

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)