Document Type

Article

Publication Date

11-2024

Abstract

A recurring problem in tax law arises when the IRS promulgates a regulation or a notice that is too favorable to taxpayers.1 The problem is that nobody has standing to challenge the regulation. The IRS cannot challenge its own regulation, and taxpayers affected by the regulation have no interest in challenging it (and even if they did, they cannot show a concrete injury sufficient to establish standing). Congress may intervene, but that is rare for a taxpayer-favorable regulation (indeed, Congress sometimes intervenes to block IRS attempts to roll back its own regulations). Taxpayers unaffected by the regulation do not have standing to protect the fisc, even though undertaxation of other taxpayers may result in increasing the tax burden on them.

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Reprinted with the permission of Tax Analysts.

Available for download on Saturday, November 04, 2034


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