Pages

▼
Tuesday, August 31, 2021

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

›
About two years ago, I posted on SSRN here an article titled The Report of the Death of the Interpretive Regulation Is an Exaggeration .  I...
Saturday, August 28, 2021

Chevron and Interpreting Through Agency Adjudications (8/28/21; 9/3/21)

›
I am updating an article I wrote earlier and realize that the working draft has some digressions in the footnotes are best eliminated from t...
Tuesday, August 24, 2021

Musing on Citation of Obvious Propositions and Footnotes (8/24/21)

›
I am working on a legal article tonight.  The issue I am concerned with is whether I need to support everything I say with some citation, us...

Other Resources for Tax Procedure (8/24/21)

›
I recently advised that I have made available on SSRN, the 2021 editions of my Federal Tax Procedure Book.  2021 Federal Tax Procedure Editi...
Thursday, August 19, 2021

The Impact of Chevron Deference is Exaggerated (8/19/21; 8/21/21)

›
I recently wrote on Judge Lauber’s Opinion in Lissack v. United States , 157 T.C. 63 (2021), here .  See Tax Court Holds that Collected Proc...
Wednesday, August 18, 2021

Tax Court Holds that Collected Proceeds for Whistleblower Awards under § 7623(b) Do Not Include Unrelated Collections (8/18/21; 8/19/21)

›
In Lissack v. United States , 157 T.C. 63 (2021), here , the Tax Court (Judge Lauber) held (quoted from the Syllabus): P filed Form 211, A...
Tuesday, August 17, 2021

Does the Form 872 Statute Extension to Date Certain Control If Normal 3-Year from Return Date Is Later? (8/17/21)

›
In United States v. Davitian (D. D.C. 8/13/21), here , the Court identified but did not decide an interesting tax procedure issue. The is...

District Court Offers Good Discussion of Claim for Refund Time Requirements in § 6511(a) & (b) (8/17/21)

›
In Libitzky v. United States , 2021 U.S. Dist. LEXIS 148037 (N.D. Cal. 8/6/21), CL here , the Court offers a good discussion of the dual sta...
Sunday, August 8, 2021

2021 Federal Tax Procedure Editions Now Available for Download on SSRN (8/8/21)

›
I have posted to SSRN the 2021 editions of my Federal Tax Procedure Book.  I have not been formally notified by SSRN that they have been acc...
Saturday, August 7, 2021

On the History of the Chevron / National Muffler Deference Kerfuffle (8/7/21)

›
Professor Jonathan Choi, here, of Minnesota Law School has published several articles on tax statutory interpretation.  He recently publishe...