Steve R. Johnson (UNLV) has has published Mayo and the Future of Tax Regulations, 130 Tax Notes 1547 (Mar. 28, 2011):

The years 2009 to 2011 have been an active period for taxpayer challenges to regulations. This has resulted in many important judicial opinions. Johnson believes the most important is the Supreme Court’s January 11 Mayo decision. Mayo makes it clear that Chevron provides the standard when tax regulations are challenged; it rejects the old view that general authority regulations receive less deference than specific authority regulations; and it confirms that Treasury and the IRS are fully subject to the usual rules of administrative law. However, it does not fundamentally change the balance between taxpayers and the government. This report examines these and other aspects of Mayo and suggests possible future battlegrounds for challenges to tax regulations.

All Tax Analysts content is available through the LexisNexis® services.