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Saturday, February 24, 2018

Congress Amends Tax Whistleblower Section, § 7623, to Clarify Broad Reading of the Award Base (2/24/18)

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Earlier this month, Congress amended the mandatory minimum tax Whistleblower award program to make clear that proceeds for purposes of the a...
Friday, February 2, 2018

Good History Lesson on the Interface of Civil Procedure and Tax Refund Suits (2/2/18)

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In United States v. Stein , 2018 U.S. App. LEXIS 2392 (11th Cir. 2018) (en banc), here , the Eleventh Circuit unanimously held that "a...
Monday, November 27, 2017

Distinguishing the Internal Revenue Code from Title 26 (11/27/17)

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In my working draft for the 2018 edition of my Federal Tax Procedure book (scheduled for publication in August 2018), I have recently revise...
Saturday, November 25, 2017

Excellent Article on the Necessity of Chevron or Something Like in the Administrative State (11/25/17)

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A significant topic in my Federal Tax Procedure book and in many tax procedure books and classes is the subject of Chevron deference.  Chev...
Wednesday, November 15, 2017

Distinguishing Legislative History from Statutory History (11/15/17)

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In my Federal Tax Procedure - (2017 Practitioners Ed. ) , here , p. 7 n. 22, I state: Legislative history is different from statutory hist...
Saturday, October 28, 2017

New Cumulative Supplement to Federal Tax Procedure Book (10/28/17)

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I provide a new cumulative supplement to the Federal Tax Procedure Book.  The cumulative supplement, dated 10/28/17, may be downloaded on th...
Thursday, October 19, 2017

More on Skidmore (10/19/17)

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I recently posted on Skidmore deference:  Other Views of Skidmore "Deference" (10/12/17; 10/15/17), here .  I offer more here on...
Thursday, October 12, 2017

Other Views of Skidmore "Deference" (10/12/17; 10/15/17)

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In my Federal Tax Procedure book (both editions), I say (footnotes omitted): Before introducing my summary of the state of the law on IRS ...
Tuesday, October 10, 2017

District Court Holds that Temporary Regulations are Legislative and Thus Fail APA's Notice and Comment Requirement (10/10/16)

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In  Chamber of Commerce v. U.S. IRS , ________ (W.D. Tex. 10/6/17), here , the Court concluded that the so-called inversion Temporary Regula...
Sunday, September 10, 2017

Federal Tax Procedure Book Revisions on Section 6110 (9/10/17)

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I posted here a new cumulative supplement, dated 9/10/17, for the Federal Tax Procedure Book.  The significant addition for this cumulative...