Document Type

Article

Comments

135 Tax Notes 651 (Apr. 30, 2012).

Abstract

The Supreme Court’s decision in Home Concrete raises new questions about the deference to be given to administrative pronouncements that conflict with prior judicial decisions. Unfortunately, the opinions of a divided Court leave practitioners to puzzle over the boundaries of its decision.

Date of Authorship for this Version

4-30-2012

Keywords

Taxation, administrative law, administrative rules and regulations, Administrative Procedure Act, APA, Treasury Regulation, judicial deference to IRS rulemaking, Chevron doctrine, Home Concrete, Mayo Foundation