Eighth Circuit Holds the Mayo in Tax Regulation Invalidity Case
By EsqSocial Corporation 18/05/21
In the latest tax regulation deference case, the Eighth Circuit provided guidance to taxpayers and tax practitioners on the “analytical path” to resolve the question of whether a tax regulation is a valid interpretation of the Internal Revenue Code. The court held that the regulation was invalid in part because it unreasonably added conditions to the statutory requirements for qualified educational organizations, however, it was valid as to its interpretation regarding the permissible scope of...
By: McDermott Will & Emery