Undoing Undue Favors: Providing Competitors with Standing to Challenge Favorable IRS Actions

Authors

Sunil Shenoi, University of Michigan Law School

Abstract

The Internal Revenue Service occasionally creates rules, notices, or regulations that allow taxpayers to pay less than they would under a strict reading of the law. Sometimes, however, these IRS actions are directly contrary to federal law and have significant economic impact. Challenging favorable IRS actions through litigation will likely be unsuccessful because no plaintiff can satisfy the requirements for standing. To address this situation, this Note proposes a statutory reform to provide competitors with standing to challenge favorable IRS actions in court.

Recommended Citation

Sunil Shenoi, Undoing Undue Favors: Providing Competitors with Standing to Challenge Favorable IRS Actions, 43 U. Mich. J. L. Reform 531 (2010).
Available at: https://repository.law.umich.edu/mjlr/vol43/iss2/7