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In this article, Tom Greenaway of KPMG's Tax Dispute Resolution Network surveys the many Administrative Procedure Act challenges to Treasury regulations. This article was originally published in the January 8, 2018 issue of Tax Notes.

The IRS and the APA: Denial Is Not a Strategy

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The following information is not intended to be “written advice concerning one or more Federal tax matters” subject to the requirements of section 10.37(a)(2) of Treasury Department Circular 230.

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