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

Eleventh Circuit Invalidates IRS Designation of Listed Transaction by Notice; Designation Must be by Notice and Comment Regulation (6/16/24)

A Reminder on Chevron in Agency Adjudications (3/25/24)

War Story-Appellate: My Early Brush (1969) with Administrative Law Meaning of Legislative Regulations (3/16/24)

Garland v. Cargill-Comments on Briefs and Oral Argument (2/29/24)

Tax Court in Reviewed Opinion Rejects Chevron and State Farm Attack on § 482 Blocked Income Regulation (2/10/23; 2/15/23)

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

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

Chevron Deference: Much Ado About Not Much (8/15/21)

§ 7805(b) Time Limits Do Not Apply to Agency Best Interpretations of the Statute (8/11/22)

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)

Chevron Spinning Uses and Abuses (4/20/22; 4/21/22)

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

Is Statutory Interpretation a Legislative Act When Agencies Do It But Not When Courts Do It? (4/8/22; 10/23/22)

Sixth Circuit Invalidates Notice Identifying Listed Transaction Requiring Reporting and Potential Penalties (3/3/22)

11th Cir. Invalidates Proportionate Sharing Regulations As Procedurally Arbitrary and Capricious for Failing to Address a Significant Comment (12/30/21; 12/31/21)

FinCEN Adopts Immediately Effective Final Rule Omitting the Regulations Statement of the 2004 Willful Penalty Prior to the 2004 Statutory Amendment (12/26/21)

Final Update of Article on APA, Legislative and Interpretive Regulations, and Chevron (12/16/21)

Sixth Circuit En Banc Panel Ties on the ATF Bump Stock Regulation, Thus Affirming Only the Judgment of the District Court Sustaining the Regulation (12/6/21)

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