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Restructuring The U.S. Tax Court: A Reply To Stephanie Hoffer And Christopher Walker's The Death Of Tax Court Exceptionalism, Leandra Lederman
Restructuring The U.S. Tax Court: A Reply To Stephanie Hoffer And Christopher Walker's The Death Of Tax Court Exceptionalism, Leandra Lederman
Articles by Maurer Faculty
This article is an invited reply to an article in the Minnesota Law Review regarding whether the “reviewing court” provisions of the Administrative Procedure Act (APA) apply to the U.S. Tax Court, the principal court hearing disputes between taxpayers and the IRS. (The Tax Court has repeatedly said that the APA does not apply to it). It argues in part that the question of whether the Tax Court must apply the APA’s standard and scope of review when reviewing IRS action is not as clear as a matter of history and doctrine as Professors Hoffer and Walker argue. The author …