Thursday, March 25, 2021
Reuven S. Avi-Yonah (Michigan), The US Taxpayer Bill of Rights: Reflections on a Toddler:
In the US the Taxpayer Bill of Rights (TBOR) is only seven years old, and moreover no successful challenge to the IRS under it has been brought so far. The following first describes the existing case law under the US TBOR. The main conclusion is that the US TBOR is a toddler with uncertain prospects.
The article then offers some observations on the application of the TBOR to corporate taxpayers.