The Four R’s Revisited: Regulations, Rulings, Reliance and Retroactivity in the 21st Century: A View from Within

August 2009
Download

This month, CCH’s Taxes – The Tax Magazine published an article authored by Mr. Korb titled, "The Four Rs Revisited: Regulations, Rulings, Reliance and Retroactivity in the 21st Century – A View from Within." The article is an update of a monograph written 40 years ago by former IRS Chief Counsel Mitchell Rogovin. Since its publication, generations of taxpayers and tax practitioners have looked to this monograph as a guide in interpreting the value and legal impact of the various forms of technical guidance issued by the Internal Revenue Service. Mr. Korb updated the article and added his own viewpoints "from within."