Tax Notes Quotes Prof. Hickman On Judicial Review of Tax Guidance

Professor Kristin Hickman was quoted in a Tax Notes article, Entering the Next Frontier of Tax and Administrative Law, regarding the broader implications of a federal district court’s holding in Bullock v. IRS, No. CV-18-103-GF-BMM (D. Mt. July 30, 2019), that the IRS violated the Administrative Procedure Act by issuing subregulatory guidance without public notice and comment procedures.  The article summarized Professor Hickman's perspective regarding the characterization of IRS guidance documents under the Administrative Procedure Act and quoted Professor Hickman as describing the Bullock decision as "a shot across the bow that [the IRS] need[s] to be more attentive to the kinds of things they are putting into subregulatory guidance."