Kristin Hickman
Associate Dean for Research and Intellectual Life
McKnight Presidential Professor in Law
Distinguished McKnight University Professor
Harlan Albert Rogers Professor in Law
Associate Director, Corporate Institute
Bloomberg Quotes Prof. Hickman on Nonprofit Donor Disclosure Case
Professor Kristin Hickman was quoted in a Bloomberg article, IRS Could Face More Court Battles After Nonprofit Donor Ruling, regarding a federal district court's holding in Bullock v. IRS, No. CV-18-103-GF-BMM (D. Mt. July 30, 2019), that the IRS violated the Administrative Procedure Act when, without public notice and comment procedures, the agency issued subregulatory guidance allowing politically active nonprofit organizations to avoid reporting the names and addresses. The article quoted Professor Hickman as saying, "The fact that the judge declared a revenue procedure to be a legislative rule is a big deal," particularly because such cases to date have been "rare."