Prof. Hickman Quoted by Bloomberg on Tax Court's Altera Decision

Professor Kristin Hickman was quoted in Bloomberg BNA's Daily Tax Report about the United States Tax Court's decision in Altera Corporation & Subsidiaries v. Commissioner, 145 T.C. No. 3 (2015), in which the Tax Court invalidated Treasury regulations implementing Section 482 of the Internal Revenue Code as arbitrary and capricious under the Administrative Procedure Act. Hickman described the Tax Court's decision as "a natural extension of the Supreme Court's reasoning in" the Supreme Court's decision in Mayo Foundation for Medical Education and Research v. United States, 131 S. Ct. 704 (2011). Moreover, she said, "[t]he fact that the Tax Court unanimously backed such a thorough application of general administrative law principles in reviewing a Treasury regulation is truly remarkable, and should send a very powerful message to Treasury and the IRS that they need to be more attentive to administrative law requirements in promulgating tax regulations."