the tax court say about the treasury’s right to apply reg retroactively? Regulation changes the definition of party, in new definition, prohibit tp. Court said that the change should going forward. You cannot change the rules in the middle and apply retroactively. there is difference btw prop reg and final reg. The court said no surprise, no big change in logic here (due process thus is not violated), anticipate the direction, and therefore no need to hold the reg invalid. temporary reg (binding):…
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