Alan Horowitz will discuss "Mayo Foundation v. U.S. on Judicial Deference to Treasury Regulations." The telebriefing, sponsored by the Law Seminars International, will take place on February 28 at 1 pm Eastern.
On January 11, 2011, the Supreme Court issued its decision in Mayo Foundation v. United States, No. 09-837. In addition to resolving a specific tax controversy about whether medical residents are exempt from Federal Insurance Contributions Act (FICA) taxation, the Court provided important guidance on the general principles for determining when courts must defer to Treasury Regulations. The Court's determination that "Chevron deference" principles should apply departs from the principles that many courts and tax lawyers have long followed and will make it more difficult for taxpayers in the future to challenge IRS positions embodied in Treasury Regulations.
In this one-hour TeleBriefing, our esteemed panel of experts will address the implications of the Mayo decision, the new questions that it raises about the scope of Chevron deference in the tax area, and the impact the decision is likely to have on future litigation and the regulatory and administrative guidance process.