Turning Chevron into the Tax Code? *

USA - February 28 2013
Every Treasury regulation cites to Code Section 7805 as the source of its authority, and the Supreme Court currently is considering a case, City of…

Co-authors: Kristyn A. Medina.

The codified economic substance doctrine: how we got here, where we are, and where we’re going next *

USA - June 19 2012
This article explores the history of efforts to codify the economic substance doctrine (the “doctrine”), the codification of the doctrine and associated strict liability penalty, and recent Treasury and IRS guidance on how Exam should apply the doctrine and penalty.

Co-authors: Alisa M. Goodwin, Joshua D Odintz.

The gift of Mayo *

USA - February 22 2012
In mid-December, the Supreme Court decided Judulang v. Holder, 565 U.S. ___ (No. 10-694, Dec. 12, 2011), an important immigration case.