Acquiescence recommended in Green Rock LLC v. Internal Revenue Serv., which held that: 1) because Notice 2017-10 did not follow notice-and-comment rulemaking procedures, the IRS violated the APA; and 2) although Treas. Reg. §1.6011-4(b)(2) provides that the IRS may list transactions by notice, a regulation without anything more cannot displace the requirements of the APA. [AOD 2024-01, 2024-52 I.R.B. (Dec. 23, 2024)]
Learn more about Bloomberg Tax or Log In to keep reading:
See Breaking News in Context
From research to software to news, find what you need to stay ahead.
Already a subscriber?
Log in to keep reading or access research tools and resources.