• Monte Silver, Tax lawyer

U.S. Supreme Court likely to prevent pre-emptive challenges to Treasury regs (but not our lawsuit!)

US Supreme Court held oral arguments in a case of CIC vs IRS, dealing with the ability of taxpayers to challenge Treasury regulations. Such challenges have been disallowed and the Supreme Court will probably uphold the prohibition. In our Transition tax case, we got around the prohibition through novel arguments, which caught the experts by surprise. For a summary of the oral hearings of the Supreme Court case see https://www.law360.com/articles/1334481

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