Federal Tax and Federal Tax Controversy + Litigation
Fogo de Chão Denver, CO
Edward L. Froelich
The presentation will cover the role of the Administrative Procedure Act in tax disputes beginning with an introductory section on the separation of powers, the purpose and scope of the APA, the development of judicial deference to agency action following which we will have a more detailed consideration of the recent developments of judicial scrutiny of Treasury actions, including promulgation of Treasury regulations, under the APA. Attendees will learn about the APA as a check on agency authority and more specifically how it can be used to evaluate the validity of Treasury actions such as formal rule-making. A basic understanding of the federal authorities involved in forming and determining tax policy is necessary for this course.
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