This amicus brief was filed before the United States Supreme Court, supporting the petition for certiorari in Florida Bankers Association v. United States Department of the Treasury, No. 15-969. The case concerns whether the Anti-Injunction Act, 26 U.S.C. s. 7421(a), precludes pre-enforcement...

This amicus brief was filed before the United States Supreme Court in United States v. Quality Stores, Inc., No. 12-1408, to discuss whether Chevron or Skidmore provides the appropriate standard for judicial review of IRS revenue rulings. The brief summarizes and expands upon arguments made in...

This amicus brief was filed before the United States Supreme Court in United States Home Concrete & Supply, LLC, No. 11-139, to discuss two issues raised by the procedures used by the Treasury Department in adopting Treas. Reg. 301.6501(e)-1, at issue in the case: (1) whether Treas. Reg....

This amicus brief was filed before the United States Supreme Court in CIC Services, LLC v. Internal Revenue Service, No. 19-930, supporting the petitioners on the merits. The issue in the case is whether the Anti-Injunction Act, 26 U.S.C. s. 7421(a), precludes pre-enforcement judicial review of...