Recent Tax Controversy Developments: The Evolving Role of the Administrative Procedure Act in Tax Disputes

Presented by Ed Froelich, Of Counsel at Morrison Foerster

The presentation will cover the role of the Administrative Procedure Act in tax disputes beginning with an introductory section on the separation of powers, the purpose and scope of the APA, the development of judicial deference to agency action following which we will have a more detailed consideration of the recent developments of judicial scrutiny of Treasury actions, including promulgation of Treasury regulations, under the APA. Attendees will learn about the APA as a check on agency authority and more specifically how it can be used to evaluate the validity of Treasury actions such as formal rule-making. A basic understanding of the federal authorities involved in forming and determining tax policy is necessary for this course.

This course qualifies for 1.0 hour of CPE in the Critical Legal and Tax Issues for Accountants field of study. It will be delivered in a live group method on October 19, 2016, from 5:00 to 5:50 pm.

This course is designed to comply with Colorado State Board of Accountancy. Participants are encouraged to confirm eligibility compliance with their jurisdiction. Refunds will be issued if the event is cancelled by FTL or for cancellations 48 hours before the start of the event. Questions, concerns, and complaints may be submitted to

To register to attend, click here. This program is free for FTL members and their guests / $35 for non-FTL members.