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Thursday, September 24, 2020

Occam’s Razor and the Distinction Between Legislative and Interpretive Regulations (9/24/20)

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I have previously said that the Administrative Procedure Act ("APA") distinction between legislative and interpretive regulations ...
Wednesday, September 23, 2020

FTPB 2020 Update 04 - Correction on GATT Corporate Overpayment Interest (9/23/20)

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The 2020 editions erroneously describe the regular corporate interest rate (2% above the federal rate) as the "GATT" rate.  The sp...
Saturday, September 19, 2020

Sunstein Blog and Article Concluding that Chevron Deference is Consistent with Original Public Meaning of the APA (9/19/20)

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In my Federal Tax Procedure Book, I deal with administrative law issues, particularly the Administrative Procedure Act (“APA”) and deference...
Wednesday, September 2, 2020

FTPB 2020 Update 03 – Central IRS Web Site for BBA Centralized Partnership Audit Regime (9/2/20)

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The IRS has announced a new website “intended to be  one-stop location for anything BBA-related, including regulations and other guidance an...
Tuesday, September 1, 2020

District Court Sustains FBAR Willful Penalty But Rejects Fraudulent Failure to File Penalty for Income Tax (9/1/20)

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 In  United States v. DeMauro  (D. N.H. Dkt. 17-cv-640-JL Order and Verdict After Bench Trial dtd. 8/28/20), CL  here , the Court sustained ...
Sunday, August 30, 2020

Citing History in Support of Statutory Meaning (8/30/20)

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This is an interesting post on history of legislation in arguing for or explaining the legislation.  Eugene Volokh, TMH (Too Much History), ...
Monday, August 24, 2020

Updated Article: The Report of the Death of the Interpretive Regulation Is an Exaggeration (8/24/20)

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I have updated my prior posting on SSRN of my article titled:   The Report of the Death of the Interpretive Regulation Is an Exaggeration . ...
Friday, August 14, 2020

FTPB 2020 Update 02 - Revised Editions of Federal Tax Procedure Book for Technical Corrections (8/14/20; 8/15/20)

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As Revised 8/15/20 In the original editions of the Federal Tax Procedure Book the headings below the Chapter level in Chapters 16 and 17 wer...
Thursday, August 13, 2020

Peter Reilly on Real Estate Phantom Taxable Income Gaming the Audit Lottery (8/13/20)

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Peter Reilly, a friend and frequent tax commenter, has this offering on his Forbes blog:  IRS Veteran Insists That IRS Is Missing Billions I...
Tuesday, August 11, 2020

Chevron and Lenity (8/11/20)

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Today, I discuss the related topics of Chevron deference and the rule of lenity.  Both topics deal with ambiguity in statutory text.  Chevr...