Document Type

Article

Publication Date

Spring 2011

Publication Title

NewsQuarterly

Publication Title (Abbreviation)

NewsQuarterly

Volume

30

First Page

11

Last Page

13

Abstract

The validity of tax regulations has been challenged by taxpayers almost as long as there have been tax regulations. Now, however, we are in a period of unusually high activity on this front. The Supreme Court recently upheld the validity of a regulation under section 3121 in Mayo Foundation for Medical Ed. and Research v. United States, 131 S. Ct. 704 (2011); many cases are testing the validity of regulations extending the six-year statute of limitations under section 6501(e) to basis overstatements (or, as the Service would put it, clarifying the law in this regard); and many cases are testing the validity of regulations imposing a two-year limitations period on claims for equitable spousal relief under section 6015(f).

Rights

Text © 2011 Steve R. Johnson

Comments

First published in ABA Section of Taxation NewsQuarterly.

Faculty Biography

http://www.law.fsu.edu/our-faculty/profiles/johnson

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