NYU School of Professional Studies Tax Controversy Forum

06.20.2019 - 06.21.2019

New York, NY

Steven Dixon will speak at the NYU School of Professional Studies Tax Controversy Forum on June 20-21, 2019, in New York, NY.  Dixon will present, "Preserving APA Challenges under the TCJA."

With the blizzard of guidance promulgated under the TCJA, challenges to many new regulations are a virtual certainty. In the meantime, the Tax Court has developed its jurisprudence on application of the APA to tax cases. Have we reached the end of "tax exceptionalism"? What does Treasury's "Policy Statement on the Tax Regulatory Process" mean for deference in tax litigation? How will the APA apply to the blizzard of new regulations under the TCJA? This panel addresses these questions and explores the current state of the law on the Administrative Procedures Act as it applies to tax.