Sunil Shenoi (J.D. 2009, Michigan; Ropes & Gray, Chicago) has published Note, Undoing Undue Favors: Providing Competitors With Standing to Challenge Favorable IRS Actions, 43 U. Mich. J.L. Reform 531 (2010).  Here is the abstract:

The IRS occasionally creates rules, notices, or regulations that allow taxpayers to pay less than they would under a strict reading of the law. Sometimes, however, these IRS actions are directly contrary to federal law and have significant economic impact. Challenging favorable IRS actions through litigation will likely be unsuccessful because no plaintiff can satisfy the requirements for standing. To address this situation, this Note proposes a statutory reform to provide competitors with standing to challenge favorable IRS actions in court.