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