Prof. Hickman Interviewed by Tax Notes Regarding Latest Anti-Injunction Act Decision

Prof. Kristin Hickman was interviewed and quoted by Tax Notes regarding the Sixth Circuit's "close call" decision to deny rehearing en banc in CIC Services, LLC v. IRS, 2019 WL 4051864 (Aug. 28, 2019).  The case concerns whether pre-enforcement judicial review of IRS Notice 2016-66 is barred by the Anti-Injunction Act, 26 U.S.C. s. 7421(a).  In the article, Appeals Court Won't Revisit Microcaptive Case in Close Call, Tax Notes quoted Prof. Hickman regarding the narrowness of the court's 9-7 decision to deny rehearing en banc and the likelihood that the Supreme Court be called upon to take up the question.  Prof. Hickman had filed an amicus brief in favor of rehearing in the case.