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Thursday, January 25, 2024

Tax Court Again Declines to Reconsider Its Holding that the Preparer's Fraud without the Taxpayer's Fraud Invokes Unlimited Statute of Limitations (1/25/24; 2/5/24)

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Long-time readers of this blog and the parallel blog Federal Tax Crimes may recall that I have had several postings on the issue of whether ...
Tuesday, January 23, 2024

Scholar Doubles Down on Erroneous Claim that APA § 706 Precludes Deference (1/23/24; 4/4/24)

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Introductory Note 4/4/24 10:00am: This blog post originally addressed a new draft article that Professor Bamzai posted on SSRN:  Aditya Bamz...
Thursday, January 18, 2024

Key Points in Oral Arguments on 1/17/24 in the Supreme Court Cases Considering the Future of Deference (1/18/24)

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I have now had the time to read the transcripts of oral arguments in the cases challenging Chevron deference: Loper Bright Enterprises v....
Tuesday, January 16, 2024

Oral Argument on 1/17/24 in Supreme Court Cases on the Future of Deference (1/16/24)

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Oral argument in the cases ( Loper Bright and Relentless , combined for oral argument) challenging Chevron deference is Wednesday, January...
Monday, January 15, 2024

NTA 2023 Annual Report and 2024 Purple Book (1/15/24)

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The National Taxpayer Advocate has issued her 2023 annual report ( here allowing download of the Full Report, the Executive Summary, and th...
Monday, January 8, 2024

Musings on Proposed § 6751(b) Regulations and the Potential Demise of Chevron Deference (1/8/24; 1/15/24)

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Section 6751(b)(1) provides: (1) In general No penalty under this title shall be assessed unless the initial determination of such asse...
Sunday, December 24, 2023

Repeat Tax Player and Republican Presidential Candidate Loses Unauthorized Return Information Disclosure Suit on Appeal (12/24/25)

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As I close out my postings for the year, I decided to report on Castro v. United States ,  2023 WL 8825316  (5th Cir. 12/21/23), unpublished...
Thursday, December 14, 2023

Article on The Tax Contribution to Deference and APA § 706 Posted on SSRN (12/14/23)

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I have just posted this article to SSRN here . The recommended SSRN cite is: Townsend, John A. and Townsend, John A., The Tax Contribution...
Tuesday, December 12, 2023

Fun Chevron: AI Weighs in on Chevron’s Future (and Golsen) (12/12/23)

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Chevron deference and its possible demise is much in the news recently with the Supreme Court’s acceptance of two parallel cases that addre...
Sunday, December 3, 2023

On the Tax Court's Golsen Rule (12/3/23; 12/5/23)

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In Kraske v. Commissioner , 161 T.C.___ No. 7 (2023), GS here , the Court provides a good application of its Golsen rule. Golsen v. Commiss...