Speaking Engagement

Tax Practice & Procedure | Testing Guidance under the Administrative Procedures Act

Federal Bar Association 2022 Tax Law Conference

03 Mar 2022 - 04 Mar 2022

Ronald Reagan Building and International Trade Center
1300 Pennsylvania Avenue NW
Washington, D.C. 20004

This panel will discuss pending litigation, including section 245A cases and the CIC Services, LLC case, currently on remand to the United States District Court, Eastern District of Tennessee. The panelists will also explore how Treasury and the IRS implement the requirement of the APA in their regulatory and sub-regulatory guidance.

Learning Objectives:

1.   Provide an overview of the Administrative Procedures Act.

2.   Review pending APA litigation, in particular the CIC Services case and Section 245A refund actions.

3.   Discuss the Treasury and the IRS implement the APA in both regulatory and sub-regulatory guidance.


  • Edward L. Froelich, Of Counsel, Morrison & Foerster LLP (Moderator)
  • David Foster, Partner, Skadden, Arps, Slate, Meagher & Flom LLP
  • Adrienne E. Griffin, Branch Chief, Branch 2, Office of Chief Counsel (P&A), IRS
  • Joseph Judkins, Partner, Baker McKenzie

Link to register.



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