Pat Smith Quoted in Tax Notes on Starr International Case

On September 22, Ivins attorney Pat Smith was quoted in a Tax Notes article on the D.C. District Court’s decision in the Starr International case on the availability of judicial review of a denial by the IRS of treaty benefits, Court Says Review of Denial of Discretionary Benefits Is Proper.

"I thought the opinion was correct on every point," said Patrick J. Smith of Ivins, Phillips & Barker Chartered. He agreed with the court that the argument that the committed-to-agency discretion exception to judicial review does not apply to a refund suit was weak. "In addition, this issue was not in fact committed to agency discretion," said Smith.