Navigating a Transition in U.S. Tax Administration

Abstract

Written for the 10th International Tax Administration Conference hosted by the School of Taxation and Business Law (Atax), Australian School of Business, The University of New South Wales, this essay summarizes and discusses the implications of three recent key cases in U.S. tax administration: Mayo Foundation for Medical Education and Research v. United States, 131 S.Ct. 704 (2011); Cohen v. United States, 650 F.3d 717 (D.C. Cir. 2011) (en banc); and United States v. Home Concrete & Supply LLC, 132 S.Ct. 1836 (2012).

Keywords: judicial review, tax administration, administrative law, Chevron, Administrative Procedure Act

JEL Classification: K23, K34