Alston & Bird Tax Blog

Administrative Procedure Act

Taxpayers Can Strike First: Supreme Court Allows Pre-Enforcement Challenges to Certain IRS Regulatory Actions

By , and

Our Federal Tax Group examines a U.S. Supreme Court ruling that could give taxpayers greater leeway to challenge IRS regulatory schemes before the IRS takes enforcement action. CIS Services v. IRS narrows the reach of the Anti-Injunction ActThree features of Notice 2016-66 helped the Court overturn lower courts’ rulings in favor of the IRSThe IRS’s rule-making process now open to more Administrative Procedure Act challenges Read the full advisory here. [...]Read more

Federal Tax Advisory: Enjoining Regulations

By

Try and try again. Our Federal Tax Group analyzes how the U.S. Supreme Court thwarted a bankers association’s attempt to circumvent the Anti-Injunction Act.

Click here to read the full advisory.