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Expert Analysis

Justices' Nod To Preemptive Tax Challenges May Caution IRS

By Robert Carney (May 26, 2021, 5:10 PM EDT) -- The U.S. Supreme Court's May 17 decision in CIC Services LLC v. Internal Revenue Service opened new possibilities for challenges to compliance with the Administrative Procedure Act with respect to U.S. Department of the Treasury regulations.[1] The government has generally attempted to prevent such challenges by asserting the so-called Anti-Injunction Act as a jurisdictional bar.[2]...

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