Prof. Hickman Quoted By Tax Notes Regarding Decision in Silver v IRS

Professor Kristin Hickman was quoted extensively in a January 9 Tax Notes article (subscription required), “Silver Strikes Gold for Tax Administrative Challenges,” regarding issues raised by a federal district court opinion and order in Silver v. IRS, Civil No. 19-cv-247 (APM) (Dec. 24, 2019), rejecting the government’s motion to dismiss a taxpayer’s challenge to Treasury regulations implementing the Tax Cuts and Jobs Act. The taxpayer challenged the regulations for failing to include an adequate evaluation of the impact on small businesses as required by the Regulatory Flexibility Act and the Paperwork Reduction Act. The article quoted Prof. Hickman extensively regarding the court’s analysis and conclusions that the taxpayer had standing to challenge the regulations and that the Anti-Injunction Act did not bar the litigation, as well as potential remedies in the event the court ultimately resolves the case in the taxpayer’s favor on the merits.