This amicus brief was filed before the United States Supreme Court, supporting the petition for certiorari in Florida Bankers Association v. United States Department of the Treasury, No. 15-969. The case concerns whether the Anti-Injunction Act, 26 U.S.C. s. 7421(a), precludes pre-enforcement...

This amicus brief was filed before the United States Supreme Court in United States Home Concrete & Supply, LLC, No. 11-139, to discuss two issues raised by the procedures used by the Treasury Department in adopting Treas. Reg. 301.6501(e)-1, at issue in the case: (1) whether Treas. Reg....

This amicus brief was filed before the United States Supreme Court in United States v. Quality Stores, Inc., No. 12-1408, to discuss whether Chevron or Skidmore provides the appropriate standard for judicial review of IRS revenue rulings. The brief summarizes and expands upon arguments made in...