The IRS' APA Rulemaking Journey: There and Back Again

Want to know more about the increased role of the Administrative Procedures Act (“APA”) in tax law? Check out our analysis published in Law360 Tax Authority on January 12, 2023, where we explore the increase in APA challenges in the tax sphere and, in particular, discuss recent taxpayer victories in Hewitt v. Commissioner, Mann Construction, Inc. v. United States, Liberty Global, Inc. v. United States, and Green Valley Investors, LLC v. Commissioner.

Read the full Law360 article here.

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About Michelle Levin

Michelle Abroms Levin is a shareholder in Dentons Sirote’s Huntsville office, where she is a member of the Tax practice group. She represents clients during all phases of federal income tax controversies, including IRS audit, administrative appeals, and court proceedings in the U.S. Tax Court, U.S. Court of Federal Claims, federal district court and the Courts of Appeals. Michelle has secured major victories for her clients in the Eleventh Circuit, Fifth Circuit, and Tax Court, elevating important Administrative Procedure Act issues in the tax controversy context. Her experience includes a wide range of complex tax issues. Michelle also counsels clients in tax and business planning. She works with clients to structure transactions in a manner that maximizes tax benefits, reduces risk, and complies with tax law at local, state, and federal levels. Michelle has also been elected as a Fellow of the American College of Tax Counsel.

About Logan Abernathy

Logan Chaney Abernathy is a Senior Managing Associate in Dentons Sirote’s Huntsville, Alabama office. She is a member of the Tax practice group. Logan’s practice focuses on tax controversy, tax litigation, and government investigations.

About Ronald Levitt

Ronald Levitt is a shareholder in Dentons Sirote’s Birmingham, Alabama office, where he is a member of the Tax practice group and leads the Dentons Sirote Conservation Easement team. His practice focuses on federal and state controversy matters, including planning and defending conservation easements.