Document / Legal Opinion

GBX Associates, LLC v. United States

Posted 2022
Source
US Tax Court
Author
Robert H. Levin
About This Legal Opinion

In December 2016, the United States Department of the Treasury and the IRS released Notice 2017-10, entitled “Listing Notice - Syndicated Conservation Easement Transactions.” GBX filed suit, claiming that the United States issued the notice without first providing any notice to the public or soliciting comments, in alleged violation of the Administrative Procedure Act (APA). The District Court denied GBX’s motion for a speedy hearing and expedited declaratory judgment.

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