Deference owed to regulations

In the past few years, we have had two US Supreme Court decisions and some from the Circuit Court of Appeals that provide some new insights into the deference owed to regulations written under the Treasury/IRS general grant of authority to provide needful rules.

I have a short article in the AICPA Corporate Tax Insider this week (6/28/21) - "Dominion Resources: Further insights into regulatory deference" that explains the topic (briefly - this is a big topic) and the case. This topic is of relevance in conducting tax research, arguing positions with the IRS, the steps federal agencies need to take in issuing guidance, and often present interesting technical issues of interpreting tax statutes.


What do you think?