Danshera Cords (Capital) presents Is Tax Special:  Administrative Law and Judicial Review of IRS Collection Decisions at the Central States Conference today in Louisville.  Here is the abstract:

Because neither tax law nor the inquiries performed by the Tax Court are unique, this article advocates that all courts apply an abuse of discretion standard to the judicial review of most IRS collection decisions that are permitted to be brought before the courts. This will require the Tax Court to reconsider its approach to the review IRS collection decisions. To conform to the standards applied by other federal courts and to satisfy the requirements set forth by Congress, the Tax Court must reconsider its position regarding the applicability of the APA and the larger body of administrative law in certain tax cases.