The Knight Watch: The Next Wave of Partnership Litigation — APA Challenges to BBA Regulations
Tax attorneys James Dawson and Lee Meyercord co-authored an article in The Tax Magazine analyzing whether an Internal Revenue Service (IRS) regulations in the Bipartisan Budget Act of 2015 (BBA) could be subject to an Administrative Procedures Act (APA) challenge. The article examines lessons from prior partnership audit rules and the legislative history of current rules. It also considers whether the IRS and U.S. Department of the Treasury adequately respond to comments on the regulation in the rulemaking process.
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