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
Faculty Biography
http://www.law.fsu.edu/our-faculty/profiles/johnson
Recommended Citation
Steve R. Johnson,
Do Treasury and the IRS Have to Explain Their Choices?, 30
NewsQuarterly
11
(2011),
Available at: https://ir.law.fsu.edu/articles/248
Comments
First published in ABA Section of Taxation NewsQuarterly.