regulation (not binding): subject to notice and comment period. No foundation and law. Going forward basis. Statue is clear, then no need for reg. final reg can be effective the date of proposed reg, so that need to be paid attention. What does 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…
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