Two recent federal district court decisions evaluated whether the process historically utilized by the Department of Treasury and the Internal Revenue Service (“IRS”) to issue guidance satisfied the requirements of the...more
On August 7, 2018, the Ninth Circuit panel vacated its earlier opinion in Altera v. Commissioner that, in a nutshell, had concluded that Treasury had complied with the Administrative Procedure Act (the “APA”) in issuing final...more
Our 26th President Theodore Roosevelt famously contributed to the American canon the following: “No man is above the law and no man is below it; nor do we ask any man’s permission when we ask him to obey it.” The notion that...more