In this Tax Notes article, Samuel Lapin examines a White House memorandum's treatment of the good cause exception to notice and comment rulemaking under the Administrative Procedure Act (APA) and the Internal Revenue Service's (IRS) early reactions to the related executive order instructing agencies to identify and rescind unlawful or potentially unlawful regulations. The memorandum promotes an expansive interpretation of the good cause exception, encouraging agencies to rescind rules without public input, an approach Lapin argues lacks legal support. He concludes that as additional rules are identified for repeal under Executive Order 14219, close attention should be paid to whether agencies follow proper procedural safeguards.