Perspective
Feb. 17, 2011
Challenging Internal Revenue Service Regulations: The U.S. Supreme Court Makes the Path More Difficult
Taxpayers challenging Internal Revenue Service regulations face an uphill battle. By Bruce Givner and Owen Kaye of Givner & Kaye.
The Internal Revenue Service issues two types of regulations. The first are issued under Internal Revenue Code Section 7805(a), which authorizes the U.S. Department of the Treasury to "prescribe all needful rules and regulations [to enforce the Internal Revenue Code], including all rules and regulations as may be necessary by reason of any alternation of law in relation to internal revenue." These are known as "interpr...
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