Brief of Amicus Curiae Professor Kristin E. Hickman In Support of Petitioners, CIC Services, LLC v. Internal Revenue Service (U.S. Sup. Ct.) (Petition Stage)

28 Pages Posted: 19 Mar 2020 Last revised: 23 Jul 2020

See all articles by Kristin E. Hickman

Kristin E. Hickman

University of Minnesota - Twin Cities - School of Law

Date Written: February 24, 2020

Abstract

This amicus brief was filed before the United States Supreme Court, supporting the petition for certiorari in CIC Services, LLC v. Internal Revenue Service, No. 19-930. The issue in the case is whether the Anti-Injunction Act, 26 U.S.C. s. 7421(a), precludes pre-enforcement judicial review of Administrative Procedure Act challenges against Treasury and IRS rules and regulations -- specifically in this case, IRS Notice 2016-66. The brief summarizes and expands upon issues raised and arguments made in some of my previous scholarship.

Keywords: Anti-Injunction Act, judicial review, Administrative Procedure Act, tax exceptionalism

JEL Classification: K23, K34, K20, K29, K40, K41, K49

Suggested Citation

Hickman, Kristin E., Brief of Amicus Curiae Professor Kristin E. Hickman In Support of Petitioners, CIC Services, LLC v. Internal Revenue Service (U.S. Sup. Ct.) (Petition Stage) (February 24, 2020). Available at SSRN: https://ssrn.com/abstract=3543680 or http://dx.doi.org/10.2139/ssrn.3543680

Kristin E. Hickman (Contact Author)

University of Minnesota - Twin Cities - School of Law ( email )

229 19th Avenue South
Minneapolis, MN 55455
United States
612-624-2915 (Phone)

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