What a way to begin. The highly respected Mr. Keith Fogg provides a long technical discussion on what we accomplished and the door this opens up. Mr. Fogg is a professor at the Harvard Law School and he heads the Harvard Law School Tax Clinic. Previously he worked at in the Office of Chief Counsel, IRS for over 30 years.
I am particularly fond of this quote:
"Of course, Mr. Silver’s case goes beyond raising the AIA challenge and throws down a significant challenge to the IRS practice of promulgating regulations as it relates to compliance with the RFA. With the initial success here, it will not be surprising to see this issue raised much more frequently as parties challenge regulations."
