Skip to Main Content
 

Christopher Rizek Talks to Law360 on U.S. Supreme Court Petition

May 17, 2019, Law360 Tax Authority

A U.S. Supreme Court petition to overturn an estate's tax liability for tens of millions of dollars could have a widespread impact on how courts can enforce ambiguous tax laws that haven't been clearly interpreted through Internal Revenue Service regulations.

. . .

Christopher Rizek, a tax attorney at Caplin & Drysdale, said that it is a novel approach to say that laws cannot be enforced when Congress has used boilerplate language for the executive branch to issue rules such as "shall prescribe" and executive agencies fail to do so.

"There are literally hundreds of places, maybe even thousands, in the Internal Revenue Code where Treasury is authorized or encouraged or told or delegated the authority and told to issue regulations," Rizek said. "I think if it were interpreted that way here, it would be a fairly chaotic result for the IRS and administrative law generally."

For the full article, please visit Law360’s website (subscription required).

Excerpt taken from the article “High Court Plea Could Undermine Tax Laws Lacking Regs” by Vidya Kauri for Law360 Tax Authority.

________________________________________________

About Caplin & Drysdale
Having celebrated our 50th Anniversary in 2014, Caplin & Drysdale continues to be a leading provider of legal services to corporations, individuals, and nonprofits throughout the United States and around the world. We are also privileged to serve as legal advisors to accounting firms, financial institutions, law firms, and other professional services organizations.

The firm's reputation over the years has earned us the trust and respect of clients, industry peers, and government agencies. Moreover, clients rely on our broad knowledge of the law and our keen insights into their business concerns and personal interests. Our lawyers' strong tactical and problem-solving skills -- combined with substantial experience handling a variety of complex, high stakes, matters in a boutique environment -- make us one the nation's most distinctive law firms.

With offices in New York City and Washington, D.C., Caplin & Drysdale's core practice areas include:
For more information, please visit us at www.caplindrysdale.com.
Washington, DC Office:
One Thomas Circle NW
Suite 1100
Washington, DC 20005
202.862.5000
New York, NY Office:
600 Lexington Avenue
21st Floor
New York, NY 10022
212.379.6000

___________________________

Disclaimer
This communication does not provide legal advice, nor does it create an attorney-client relationship with you or any other reader. If you require legal guidance in any specific situation, you should engage a qualified lawyer for that purpose. Prior results do not guarantee a similar outcome.

Attorney Advertising
It is possible that under the laws, rules, or regulations of certain jurisdictions, this may be construed as an advertisement or solicitation.
© 2019 Caplin & Drysdale, Chartered
All Rights Reserved.

Related Professionals

Related Practice Area(s)