Alan Horowitz comments on the Supreme Court’s September 27 decision to grant certiorari in Home Concrete & Supply LLC v. United States, to review the Fourth Circuit's interpretation of Internal Revenue Code section 6501(e). The case "tees up a number of uncertain issues in the intersecting areas of tax and administrative laws, so Supreme Court review provides an opportunity for the Court to provide more certainty about Treasury's ability to promulgate new rules in the face of contrary judicial decisions and how far those rules can go in their substantive effect on past tax years," Horowitz says.

This quote also appeared in the January 2, 2012 edition of Tax Notes Today.