Forbes: IRS Issues Final Regulations Limiting Appeals Review Of IRS Guidance
In recent years, the IRS has taken a more defensive posture as it seeks to have federal courts validate its guidance. Indeed, many federal courts have overruled such guidance on procedural grounds, such as the agency’s failure to comply with the Administrative Procedure Act. After the Supreme Court’s 2024 decision in Loper Bright, we can expect these types of challenges to continue on both substantive and procedural grounds.