Alan Horowitz's comments on the Supreme Court's upcoming review of the Fourth Circuit's Home Concrete decision appear in Tax Notes Today's year in review. Horowitz said Home Concrete involves "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."

This quote previously appeared in a September 28, 2011 article in the same publication.