Patrick Smith Recently on List of Top Ten Downloads for U.S. Administrative Law e-JournalPDF
Ivins attorney Patrick Smith’s 2012 Tax Notes article The APA’s Arbitrary and Capricious Standard and IRS Regulations was recently listed on the SSRN list of top ten weekly downloads for the U.S. Administrative Law e-journal. Recent interest in this article was undoubtedly prompted by the Tax Court’s recent unanimous court-reviewed opinion in Altera Corp. v. Commissioner, which was the first time the Tax Court had invalidated an IRS regulation under the APA’s arbitrary and capricious standard.