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Anti-Injunction Act

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

May 24, 2021 By George Abney, Laura Gavioli and Eli McCrain

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

Filed Under: Federal Tax Advisory Tagged With: Administrative Procedure Act, AIA, Anti-Injunction Act, CIS Services, IRS, Notice 2016-66, SCOTUS, Supreme Court

The Treasury’s New Guidance Policy

April 2, 2019 By Jasper L. (Jack) Cummings, Jr.

What guidance has the “force and effect of law”? Our Federal Tax Group dives into an appeal of a court case involving Notice 2016-66, the Anti-Injunction Act, and a new Treasury policy statement that could upset the department’s applecart.

A new transaction of interest: micro-captive transactions
Policy Statement on the Tax Regulatory Process
Eviscerating the premise of an argument

Read the full advisory here. [...]Read more

Filed Under: Federal Tax Advisory Tagged With: Anti-Injunction Act, IRS, micro-captive transactions, Treasury

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