Paul L. Caron

Wednesday, December 4, 2013

More on United States v. Woods

Supreme CourtFollowing up on yesterday's posts (here and here) on the Supreme Court's unanimous decision in United States v. Woods, No. 12-562 (Dec. 3, 2013)

Tax | Permalink


The Grewal article is interesting. He says that the taxpayer in Woods failed to make a Temporary Regulations, Mayo, argument that might well have won the case for them. If so, this illustrates two things: ]
1. Tax lawyers haven't "gotten it" that the APA applies to Treasury, as Mayo said.
2. Amicus briefs now would be especially helpful to courts, because of (1).

Posted by: Eric Rasmusen | Dec 5, 2013 10:21:43 AM