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Alan Horowitz Quoted Regarding Decision Allowing IRS to Fight Challenges to Old Regs in Law360

Subtitle
"3rd Circ. Gives IRS Ammo In Fighting Challenges To Old Regs"

Law360

Alan Horowitz was quoted regarding the Third Circuit's recent decision that the IRS wasn't expected to predict every possible impact of decades-old tax regulations, which could impact future challenges to rules written years ago. Horowitz said the panel wanted to reconfirm and highlight the principle of assessing the validity of a regulation at the time it is promulgated. "Therefore, for future challenges that come up to regulations that have been on the books for a while, they've given the courts a reminder or ammunition for being skeptical about arguments that are going to rely, to an extent, on things that happened after a regulation came out," he added.