So you want to challenge a Treasury regulation issued under the TCJA?
Updated: Mar 16
A 2500 word article of mine published in Tax Notes Federal, a weekly online and print journal of Tax Notes.
The article provides a step by step in depth analysis of (i) the RFA & PRA, (ii) how we used them to sue the government and defeat their motion to dismiss, and (iii) the implications for the future. Full of footnotes and references to outside material. the article is intended to give others a clear roadmap as to how to file their own lawsuits
For full article, click here: https://drive.google.com/file/d/1lIsDNpxFQLwTkIgF1FGT_WA3yiy_hLh9/view?usp=sharing