The ruling provides a new avenue for parties to bring pre-enforcement challenges to IRS rules and regulations.
..In CIC Services v. IRS, the US Supreme Court allowed a pre-enforcement challenge to an IRS reporting rule to go forward, thereby expanding the universe of suits that may survive an Anti-Injunction Act challenge.
..Parties seeking to bring a pre-enforcement challenge must identify a non-tax obligation that will be alleviated through their suit. Pre-enforcement suits by parties who would otherwise need to risk criminal liability are more likely to survive.
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