A Concrete Shoe for Brand X?
David J. Shakow
University of Pennsylvania Law School; Chamberlain Hrdlicka
April 30, 2012
Tax Notes, Vol. 135, p. 651, April 2012
U of Penn, Inst for Law & Econ Research Paper No. 12-21
The Supreme Court’s decision in Home Concrete raises new questions about the deference to be given to administrative pronouncements that conflict with prior judicial decisions. Unfortunately, the opinions of a divided Court leave practitioners to puzzle over the boundaries of its decision.
Number of Pages in PDF File: 4
Keywords: Taxation, administrative law, administrative rules and regulations, Administrative Procedure Act, Treasury Regulation, judicial deference to IRS rulemaking, Chevron doctrine, Home Concrete, APA, Mayo Foundation
JEL Classification: K23, K34
Date posted: May 4, 2012