A Concrete Shoe for Brand X?

Authors

David J. Shakow, University of Pennsylvania Carey Law SchoolFollow

Document Type

Article

Publication Date

4-30-2012

Abstract

The Supreme Court’s decision in Home Concrete raises new questions about the deference to be given to administrative pronouncements that conflict with prior judicial decisions. Unfortunately, the opinions of a divided Court leave practitioners to puzzle over the boundaries of its decision.

Keywords

Taxation, administrative law, administrative rules and regulations, Administrative Procedure Act, APA, Treasury Regulation, judicial deference to IRS rulemaking, Chevron doctrine, Home Concrete, Mayo Foundation

Publication Title

Tax Notes

Publication Citation

135 Tax Notes 651 (Apr. 30, 2012).

Repository Citation

Shakow, David J., "A Concrete Shoe for Brand X?" (2012). All Faculty Scholarship. 410.
https://scholarship.law.upenn.edu/faculty_scholarship/410