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A New Paradigm For Irs Guidance: Ensuring Input And Enhancing Participation, Leslie Book

Leslie Book

This article highlights how, in light of the increasing role that the IRS plays in the lives of poorer and marginalized individuals, when promulgating rules, the IRS will have to go beyond the mechanism of the APA notice and comment regime to ensure robust public participation. While others have discussed the IRS’s approach to the notice and comment regime, commentators generally have overlooked the problems associated with lower income taxpayers’ lack of voice in the rulemaking process. To remedy that shortfall, I call for changes in agency conduct to encourage public participation in formulating rules. I build upon a model …