Publication Title (Abbreviation)
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).
Text © 2011 Steve R. Johnson
Steve R. Johnson,
Do Treasury and the IRS Have to Explain Their Choices?, 30
Available at: https://ir.law.fsu.edu/articles/248