Pat Smith Quoted in the Daily Tax Report on the Importance of the Altera Case

Ivins attorney Pat Smith was quoted in an article in Bloomberg BNA’s Daily Tax Report on recent cases dealing with the application to tax regulations of the Administrative Procedure Act’s requirement to use notice-and-comment procedures in issuing regulations. Tax Administrative Law Challenges Pick Up Momentum.

The Tax Court's 2015 ruling in favor of Altera was “the first time the Tax Court seriously considered an APA-based argument” that concluded “the IRS and Treasury hadn't properly followed the rules that applied to issuing regulations,” Patrick J. Smith, a partner at Ivins, Phillips & Barker, Chartered, said.