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Zhanna Ziering Comments on Temporary Regs' Validity Without Notice and Comment

October 10, 2018, Tax Notes

Even after a noteworthy loss in district court with a rather bland appellate conclusion, the government is not giving ground on its assertion that temporary regs are valid without notice and comment. . . . At the American Bar Association Section of Taxation meeting in Atlanta . . . Zhanna A. Ziering of Caplin & Drysdale said she wondered if the lower court’s decision might result in a delay in the issuance of future temporary regs as they awaited notice and comment in the future or whether Treasury might state a good cause exception for why notice and comment was not required.

For the full article, please visit Tax Notes’ website (subscription required).

Excerpt taken from the article “DOJ Sticking to Its Guns in Defense of Temporary Regs' Validity” by Andrew Velarde for Tax Notes.


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